-35-
a. Travel
Petitioners argue that they have substantiated $5,978 of
expenses claimed as travel expenses for 1997 through the
introduction of Exhibit 112-P. We disagree. Exhibit 112-P was
received into evidence through the parties’ stipulation that the
exhibit reflects “documents which Petitioners contend pertain to
business meals, travel and lodging incurred in taxable year
1997”. Exhibit 112-P has approximately 75 pages, and petitioners
have not organized or presented the “documents” included therein
(mainly photocopies of receipts) in a manner that persuades us
that any of the expenses reflected in this exhibit are properly
deductible by petitioners. See Romer v. Commissioner, T.C. Memo.
2001-168. Nor do petitioners in their posttrial opening brief
make any concerted attempt to persuade us that they have
satisfied the requirements for deductibility; petitioners’ entire
argument on this point is that “These travel expenses are
substantiated in Exhibit 112-P and should be allowed.” We
sustain respondent’s determination that petitioners are not
entitled to deduct these claimed expenses.14
14 We note that during respondent’s audit of the subject
years Michelsen prepared a “travel expense record” for 1997 and
that this expense record was admitted into evidence as part of
Exhibit 135-P. The expense record is an 8-page document that
lists in single spaces each day in 1997 (i.e., 01/01/97,
01/02/97, and so on). To the right of some of the days is a
brief statement by Michelsen as to the business that she
performed for the Nature’s Touch shops on the corresponding day,
(continued...)
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