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* * * * * * *
unless the taxpayer substantiates by adequate records
or by sufficient evidence corroborating the taxpayer's
own statement (A) the amount of such expense or other
item, (B) the time and place of the travel,
entertainment, amusement, recreation, or use of the
facility or property, * * * (C) the business purpose of
the expense or other item, * * *
The requirements of section 274(d) are designed to ensure
taxpayers maintain records and documentation sufficient to
substantiate each expense claimed as a deduction. See Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985). Without business
records or other proof to substantiate that those expenses were
incurred for business purposes, a taxpayer is not entitled to
such deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Petitioner has presented no evidence concerning any rent
payments paid by GTG for 1999. Thus, without any evidence to
substantiate the claimed expenses, we find that petitioner is not
entitled to any rent expense deduction in excess of the $2,850
allowed by respondent.
With respect to the travel and entertainment expenses for
both 1999 and 2000, petitioner’s evidence consisted of financial
records in the form of copied receipts, bills, credit card
statements, and a single expense report from a GTG employee.
Petitioner did not offer any testimony as to the business purpose
of any of the expenses noted in the financial records. For
example, while the expense report vaguely listed several costs,
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