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Since petitioner did not provide any other substantiation, he is
not entitled to deductions for car and truck expenses.
b. Meals and Entertainment Expenses
Petitioner claimed deductions of $1,250 for meals and
entertainment expenses, before the application of section 67.
Petitioner indicated on the spreadsheet that he paid $466.09 for
meals in connection with Zomans Productions. Petitioner contends
that he met regularly with four or five clients. Petitioner
presented a 2002 calendar which he claims noted the dates when he
took a client to lunch or dinner. The calendar, however, did not
make any cross-references to the spreadsheet, and the Court is
therefore unable to determine when the expenses were paid.
Moreover, the calendar failed to specify, as required by the
regulations, who the clients were, the nature of the clients’
business relationship with petitioner, the business purpose of
the meals, and the locations of the meals. See sec. 1.274-
5T(b)(3), (c), Temporary Income Tax Regs., 50 Fed. Reg. 46015,
46016 (Nov. 6, 1985).
The Court finds that the evidence petitioner presented is
insufficient to satisfy the strict substantiation requirements of
section 274(d). Since petitioner did not provide any other
substantiation, he is not entitled to deductions for meals and
entertainment expenses.
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