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distinguish among his clients, NPC’s clients, and Wise’s clients,
but his attempts, for the most part, were lost on the Court.
This lack of detail, exacerbated by a lack of precision, does
little to demonstrate how many of the disallowed deductions
relate to petitioner’s trade or business. Furthermore,
complications between the parties that arose in the pretrial
stipulation process, see Rule 91, resulted in a hodgepodge of
exhibits, some of which duplicate others in content if not
format, many of which are illegible or incomplete, and many of
which, although it might come as a surprise to the parties, are
hardly self-explanatory.
As we have noted in countless cases, deductions must be
substantiated by adequate records. Sec. 6001; Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Not only does the taxpayer bear the burden
to substantiate any deduction claimed, but in proceedings such
as this one, the taxpayer has the burden to present the
substantiating records in an organized manner that clearly
demonstrates the relationship of the record to the disputed
deduction.
1. Deductions for Expenses Other Than for Commissions and Fees
The documents that petitioner produced to substantiate the
deductions claimed for expenses other than for commissions and
fees consist of: (1) Copies of receipts from various restaurants
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