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taxpayer must provide adequate records or corroborating evidence
showing the costs of the gifts, the dates the gifts were made,
descriptions of the gifts, the business purposes of the gifts,
and the business relationships between the taxpayer and the gift
recipients. Sec. 274(d); sec. 1.274-5T(b)(5), (c), Temporary
Income Tax Regs., 50 Fed. Reg. 46016-46017 (Nov. 6, 1985).
Petitioner introduced no evidence showing the dates of the
gifts and provided only vague, uncorroborated testimony regarding
the business purposes of the gifts and his relationships with the
recipients. Therefore, we agree with respondent that petitioner
is not entitled deduct the costs of the business gifts for 2003.
3. Entertainment and Business Meals
Under section 274(d)(2), a taxpayer may not claim a
deduction for entertainment expenses unless the taxpayer meets
the strict substantiation requirements. To substantiate such an
expenditure, a taxpayer must provide adequate records or have
sufficient evidence corroborating the amount of the expenditure,
the date of the entertainment, the location of the entertainment,
the business purpose of the entertainment, and the business
relationship between the taxpayer and the person entertained.
Sec. 1.274-5T(b)(5), Temporary Income Tax Regs., supra.
Petitioner asserts that he is entitled to a deduction of 50
percent of $977, which he allegedly spent on meals and
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