-39-
persuaded us as to the specifics of their day-to-day activities
while in Australia or, more specifically, the amount of time that
they purportedly spent on business versus personal pursuits.
Exhibit 123-P was received into evidence through the parties’
stipulation that the exhibit reflects “documents which
Petitioners contend pertain to business related travel for
taxable year 1999”. Exhibit 123-P has approximately 70 pages,
and petitioners have not organized or presented the “documents”
included therein (mainly photocopies of receipts) in any manner
that persuades us that any of the expenses reflected in this
exhibit are properly deductible by petitioners. Nor do
petitioners in their posttrial opening brief persuade us that
they have satisfied the requirements for deductibility;
petitioners’ entire argument on this point is:
The trip had a clear business purpose. Ms. Michelsen
was actively pursuing a business expansion.
(TR169:16-171:1) Substantiated costs total $12,847
(Exhibit 123-P). Only one-third of this expense was
allocated to business. A deduction of $4,129, which
was taken on the return, should be allowed.
We sustain respondent’s determination that petitioners are not
entitled to deduct these claimed expenses.
c. Meals
Petitioners argue that they have substantiated the $9,789 of
expenses claimed as a meals deduction for 1999 through the
introduction of Exhibit 124-P. We disagree. Exhibit 124-P was
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