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lishes only the daily amount deemed spent for meals while travel-
ing away from home on business. Sec. 1.274-5(j)(1), Income Tax
Regs. The taxpayer must still establish the time, the place, and
the business purpose of the daily expenditures for meals. Id.
In support of their position that they are entitled for
their taxable year 2002 to deduct job expenses in excess of the
amount allowed by respondent, petitioners rely on, inter alia,
two documents. The first document (document one) is a 12-page
calendar for 2002, with one page for each month of that year.
For each month in document one, Mr. Shoemaker made entries6 on
certain days of the respective job site locations at which peti-
tioners claim he worked, the respective miles that petitioners
claim he drove between petitioners’ residence and such job site
locations, and the respective parking fees and tolls that peti-
tioners claim he paid.7 For each month in document one, Mr.
Shoemaker made entries that he claims were the respective totals
of the daily entries of the number of days worked, the miles that
petitioners claim he drove between petitioners’ residence and the
job site locations at which petitioners claim he worked, and the
6Mr. Shoemaker initially testified that during 2002 he made
entries on a daily basis in document one. He changed his testi-
mony on cross-examination. During cross-examination, Mr. Shoe-
maker testified that during 2002 he made entries on a weekly
basis in document one.
7Mr. Shoemaker labeled the daily entries for parking fees
and tolls “Toll” or “T”.
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