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lodging, meals, and certain unidentified travel purposes that are
at issue. See sec. 1.274-5T(c)(1), Temporary Income Tax Regs.,
50 Fed. Reg. 46016-46017 (Nov. 6, 1985). Although petitioner
testified about document one and document two, we found his
testimony to be sparse, vague, general, and conclusory. We do
not find his testimony to be the type of reliable corroborative
evidence required to support a record or statement not made at or
near the time of the use or expenditures at issue. See id. We
are unwilling to rely on document one, document two, and peti-
tioner’s testimony to establish petitioner’s position with re-
spect to the claimed expenditures for the use of his automobile,
lodging, meals, and certain unidentified travel purposes.9
On the record before us, we find that petitioner has failed
to carry his burden of establishing that he is entitled for his
taxable year 2002 to the deductions that he claims for expendi-
tures for the use of his automobile, lodging, meals, and certain
unidentified travel purposes.
Claimed Unidentified Business Expenses
Petitioner presented no evidence and advances no argument
with respect to the unidentified business expenses for which he
9Assuming arguendo that we had found document one, document
two, and petitioner’s testimony to be reliable, those documents
and that testimony do not establish all of the elements that
petitioner must prove in order to satisfy the requirements under
sec. 274(d). See sec. 1.274-5T(b)(2), Temporary Income Tax
Regs., 50 Fed. Reg. 46014-46015 (Nov. 6, 1985).
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