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petitioner’s consulting activity. They also deducted expenses
for meals and entertainment of $457 for 1999, $1,780 for 2000,
and $575 for 2001.
No deduction is allowed for expenses for travel, meals,
entertainment, or lodging unless the taxpayer substantiates by
adequate records or sufficient evidence corroborating the
taxpayer’s own statement, the amount, time and place, and
business purpose of the expense. Sec. 274(d). Petitioners
offered no evidence showing how much they spent for petitioner’s
consulting activity.
Hughs asked petitioners to provide documentation for
petitioner’s travel, entertainment, meals, and lodging expenses.
Petitioners did not give that documentation to respondent or
offer it as evidence. We infer that petitioner did not keep a
contemporaneous log of those expenses. We conclude that
petitioners may not deduct expenses for travel, meals, or
entertainment for the years in issue because they have not met
the substantiation requirements of section 274(d).
6. Utility Expenses
Petitioners deducted electricity expenses of $949 for 1999
and $444 for 2000 for their residence on the Schedules C for
petitioner’s consulting activity. Petitioners did not offer any
evidence showing that petitioner used any part of their home
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