Jack C. Goins, Sr. and Edith M. Goins - Page 8




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          v. Flowers, supra at 470.  If a taxpayer’s otherwise deductible             
          traveling expenses are reimbursed by his employer, the taxpayer             
          is entitled to a deduction only for amounts in excess of the                
          reimbursements, and only if properly substantiated.  See sec.               
          1.162-17(b)(3), Income Tax Regs.; sec. 1.274-5T(f)(2)(iii),                 
          (5)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46028 (Nov. 6,             
          1985).                                                                      
               Section 274(d) imposes stringent substantiation requirements           
          for deductions related to travel, entertainment, gifts, and                 
          “listed property (as defined in section 280F(d)(4))”.  Otherwise            
          allowable deductions for these types of expenses are not allowed            
          unless:                                                                     
               the taxpayer substantiates by adequate records or by                   
               sufficient evidence corroborating the taxpayer's own                   
               statement (A) the amount of such expense or other item,                
               (B) the time and place of the travel, entertainment,                   
               amusement, recreation, or use of the facility or                       
               property, or the date and description of the gift, (C)                 
               the business purpose of the expense or other item, and                 
               (D) the business relationship to the taxpayer of                       
               persons entertained, using the facility or property, or                
               receiving the gift. * * *                                              
          Sec. 274(d).                                                                
               To substantiate his traveling expenses, petitioner produced            
          a travel log and numerous credit card receipts.  According to               
          petitioner, expenses incurred in connection with his employment             
          with the DOI are recorded in the travel log.  On a day-by-day               
          basis, petitioner’s travel log lists expenses for breakfast,                
          lunch, dinner, business meals, entertainment, tips (generally for           





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