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there by the Irish government”. He likewise asserted globally
that he had never taken a vacation or an airline trip for
personal reasons during the years in issue. No details of any of
the trips were offered.
Leaving aside other potentially applicable limitations, the
Court observes that any deduction for travel would at minimum
require compliance with the strict substantiation provisions of
section 274(d). Yet Mr. Deihl’s testimony in this regard, not to
mention the uninformative credit card documents, falls woefully
short. We do not even know the dates of the travel. No
deduction is permitted.
K. Contributions
Petitioners’ records or testimony link several expenditures
to the idea of a contribution and/or charitable entity. For
example, concerning an $800 May 6, 1996, Mayor check to New
Arizona Family characterized in the general ledger as for “Golf
Registration”, Mr. Deihl testified: “The New Arizona Families,
it’s a charity here in town that we helped co-sponsor and
participated in a golf outing with them.” Petitioners sought to
deduct the amount under training, meetings, and/or conventions.
A $1,000 June 3, 1997, KareMor charge to Phoenix Zoo was labeled
on credit card statements as “ADMISSION/TICKETS”, but Mrs. Deihl
testified: “I would assume it was a donation to the Phoenix
Zoo.” The amount was claimed under promotion.
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