-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.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40Last modified: November 10, 2007