Jin Xiong - Page 15

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          expenses, is subject to the strict substantiation requirements of           
          section 274.  Sec. 274(d)(2).  Petitioner submitted receipts for            
          restaurant meals which show the dates and amounts of the meals              
          but not the business purpose of the meals or the business                   
          relationship to petitioner of persons with whom he shared the               
          meals.  See sec. 274(d) (flush language); sec. 1.274-5T(b),                 
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              
          Petitioner’s testimony in this regard was vague and unconvincing,           
          and the record does not meet the statutory requirements for                 
          substantiation, even if the claimed expense might be allowable if           
          incurred while away from home in pursuit of a trade or business.            
          The claimed deduction for meals represents a personal expense and           
          is not allowable.  See sec. 1.262-1(b)(5), Income Tax Regs.                 
               Petitioner deducted the trading costs he incurred in                   
          purchasing and selling securities held in his Roth IRA.                     
          Petitioner does not claim to be a dealer in securities, nor does            
          he point to any statutory provision that might justify treating             
          his trading costs other than in the usual manner, as additions              
          to, or subtractions from, his basis for purposes of computing               
          gain or loss on sale.  See sec. 1221; Woodward v. Commissioner,             
          397 U.S. 572, 575 (1970); sec. 1.263(a)-2(e), Income Tax Regs.              
          These trading costs are not deductible.                                     
               In his amended return, petitioner sought to deduct $16,561             
          under section 179 with respect to the business use of a motor               

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