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expended or billed amounts are equally consistent with a business
purpose and with a personal, living, or family purpose. While
trade- or business-connected expenses are deductible, personal,
living, and family expenses are not. Compare sec. 162(a)
(allowing as a deduction “all the ordinary and necessary expenses
paid or incurred during the taxable year in carrying on any trade
or business”) with sec. 262 (disallowing, generally, a deduction
for “personal, living, or family expenses”). While some of the
documents are annotated, e.g., dollar amounts circled or a name
appearing next to a country club charge for a restaurant lunch,
there is insufficient information on the documents or in
petitioner’s testimony to show any business connection for any of
the expenses. There is, for instance, no evidence to show the
business connection of a VISA credit card charge of $209 for an
airline ticket. The charge shows no travel date or itinerary and
is annotated only “T/E”, which we assume stands for “travel and
entertainment”. Indeed, petitioner has made no attempt to show
that he has met the stringent substantiation requirements imposed
by section 274 and applicable generally to business-related
travel and entertainment expenses. Petitioner has failed to
convince us that any of the Schedule C expenses were incurred in
4(...continued)
support the claims, petitioner claims that he has been a
financial consultant for over 20 years and, during 2000, was also
“in the business of second mortgage placing” and “individual
retirement account investments.”
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