-40-
received into evidence through the parties’ stipulation that the
exhibit reflects “documents which Petitioners contend pertain to
overnight business meal expense for taxable year 1999”. Exhibit
112-P has approximately 20 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 as “meals”. 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 such deductibility; petitioners’
entire argument on this point is that “Expenses incurred are
substantiated in Exhibit 124-P. Total expenses are $9,789.” We
sustain respondent’s determination that petitioners are not
entitled to deduct these claimed expenses.
E. Epilogue
We have considered all of the parties’ arguments, and all
arguments not discussed herein have been rejected as moot,
irrelevant, or without merit.
Decision will be entered
under Rule 155.
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