- 6 -                                         
          therefore have failed to meet the strict substantiation                     
          requirements of section 274(a) and (d) that would allow a                   
          deduction.                                                                  
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered for respondent.             
Page:  Previous  1  2  3  4  5  6  7
Last modified: November 10, 2007