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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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