Carl Albert and Lorraine Rouse - Page 9

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          complies with certain strict substantiation rules, no deduction             
          is allowable (1) for traveling expenses, (2) for entertainment              
          expenses, (3) for expenses for gifts, or (4) with respect to                
          listed property.  Listed property includes passenger automobiles            
          and other property used as a means of transportation.  Sec.                 
          280F(d)(4).  To meet the strict substantiation requirements, the            
          taxpayer must substantiate the amount, time, place, and business            
          purpose of the expenses.  Sec. 274(d); sec. 1.274-5T, Temporary             
          Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).                        
               In order to substantiate the amount of expenses for listed             
          property, a taxpayer must establish the amount of business use              
          and the amount of total use for such property.  Sec. 1.274-                 
          5T(b)(6)(i)(B), Temporary Income Tax Regs., 50 Fed. Reg. 46006              
          (Nov. 6, 1985).  With respect to the use of automobiles, in order           
          to establish the amount of an expense the taxpayer must establish           
          the amount of business mileage and the amount of total mileage              
          for which the automobile was used.  Id.  The taxpayer may                   
          substantiate the amount of mileage by adequate records or by                
          sufficient evidence corroborating his own statement.  Sec.                  
          274(d).  A record of the mileage made at or near the time the               
          automobile was used, supported by documentary evidence, has a               
          high degree of credibility not present with a subsequently                  
          prepared statement.  Sec. 1.274-5T(c)(1), (2), and (3), Temporary           
          Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).                        






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