The petitioner was in the business of building and repairing radio towers which required him to drive long distances. He prepared handwritten invoices after a job was completed which he kept in a metal box and kept receipts for business expenditures in plastic bags with index cards that showed the amounts and types of expenses. The petitioner claimed almost $140,000 of related expenses for the year at issue. IRS largely denied the expense deductions for lack of substantiation. Reconstructed calendar inadequate to substantiate expenses. Fraud penalty not upheld, but accuracy-related penalty imposed. Flake v. Comr., T.C. Memo. 2014-76.