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amount of such expense or other item, the time and place of the
expense, the business purpose of the expense, and the business
relationship to the taxpayer of the person entertained. See sec.
274(d); sec. 1.274-5T, Temporary Income Tax Regs., 50 Fed. Reg.
46014 (Nov. 6, 1985). We may not estimate expenses subject to
the strict substantiation requirements. Sanford v. Commissioner,
50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir.
1969).
Petitioner contests respondent’s disallowance of car and
truck, travel, and meals and entertainment expenses. Petitioners
offered no testimony as to what car and truck, travel, and meals
and entertainment expenses were incurred and introduced no
documentation. We conclude that petitioners have failed to
substantiate any of the expenses subject to the strict
substantiation requirements of section 274(d) and therefore are
not entitled to any deduction beyond what respondent previously
allowed.
III. Unreported Rental Income
We now address whether petitioners failed to report $3,424
of rental income in 1996 as respondent determined. Petitioners
did not introduce any evidence at trial regarding respondent’s
determination of the unreported rental income and did not address
this determination in their brief. We conclude that petitioners
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