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however, at the very least his testimony casts doubt on his
assertion that WTS was a separate business.5
Even if WTS was a separate business, each of the claimed
expense deductions fails to satisfy one or more requirements to
be deductible. With respect to travel, meals, and entertainment
expenses, petitioner has not met the substantiation requirements
of section 274(d). Although petitioner introduced a number of
receipts, they do not describe the business purpose of the
expenses or the business relationship to petitioner of the
persons he entertained. See sec. 274(d); sec. 1.274-5T(b),
Temporary Income Tax Regs., supra.
Petitioner testified that he purchased a vehicle that he
used exclusively for WTS-related business, even though title to
the vehicle was held in petitioners’ names rather than in WTS’s
name. Because the vehicle was listed property as defined in
section 280F(d)(4)(A), deductions related to the vehicle are also
subject to the heightened substantiation requirements of section
274(d). Petitioner did not keep a mileage log, however, or
otherwise corroborate his testimony concerning the business
purpose of the vehicle. See sec. 274(d); sec. 1.274-5T(c),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
5 Petitioner’s belief that WTS was related to his employment
with SBOE may explain why he originally claimed the $12,488 of
additional Schedule C deductions as unreimbursed employee
expenses. See supra note 3.
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