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time of the expenditure. See sec. 1.274-5T(c)(2), Temporary
Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). In
addition, the taxpayer must supply documentary evidence such as
receipts or paid bills. See sec. 1.274-5T(c)(2)(iii), Temporary
Income Tax Regs., 50 Fed. Reg. 46019 (Nov. 6, 1985). A taxpayer
who is unable to meet the adequate records standard may be able
to substantiate travel expenses with his own statements
containing specific details of each element, in conjunction with
other corroborative evidence of each element. See sec. 1.274-
5T(c)(3), Temporary Income Tax Regs., 50 Fed. Reg. 46020 (Nov. 6,
1985).
Although the parties agreed at trial that petitioner paid
rent for the apartment in Orange, California, petitioner failed
to substantiate the rent payments as travel expenses related to
his business. He failed to provide any records indicating the
dates of travel or the specific purpose for each trip. In
failing to provide an account book, diary, log, or any other
specific record of his travel and expenditures, petitioner failed
to meet the adequate records standard.
Petitioner also flunked the alternative test. His testimony
failed to set forth with any particularity the dates and times of
his travel or the specific business purpose for each trip. Nor
did petitioner produce any witnesses or any other evidence to
corroborate when and how often he used the apartment and that
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