Michael E. Thibodeaux & Stephanie R. Thibodeaux, a.k.a. Stephanie R. Hearn - Page 8

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          thereto when generally there is a lack of accurate recall.”  Sec.           
          1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46017              
          (Nov. 6, 1985).                                                             
               We turn our attention first to the deduction for meals and             
          entertainment.  According to petitioner, whatever receipts for              
          those expenses he at one time had, but turned over to his                   
          accountant, have been lost, and nothing in the record suggests              
          that petitioner contacted any third parties in an attempt to                
          obtain duplicates of those records.  Furthermore, according to              
          petitioner, he at no time recorded such expenses in a                       
          contemporaneously maintained diary.  Petitioner’s “diary”                   
          prepared long after the events recorded in it, in and of itself,            
          is not sufficient to satisfy the substantiation requirements                
          discussed above.  See Hentges v. Commissioner, T.C. Memo. 1998-             
          244.                                                                        
               Because petitioners have failed to satisfy the applicable              
          substantiation requirements with respect to expenses for meals              
          and entertainment, they are not entitled to a deduction for those           
          expenses.  Respondent’s disallowance of that deduction is                   
          sustained.                                                                  
               The dispute between the parties as to petitioners’                     
          entitlement to a deduction for travel expenses now is limited to            









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