Frederick Douglas Abdullah - Page 14

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          Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d            
          201 (2d Cir. 1969).  Section 274(d) imposes strict substantiation           
          requirements for listed property as defined in section                      
          280F(d)(4), gifts, travel, entertainment, and meal expenses.                
          Sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014            
          (Nov. 6, 1985).  To obtain a deduction for a listed property,               
          travel, meal, or entertainment expense, a taxpayer must                     
          substantiate by adequate records or sufficient evidence to                  
          corroborate the taxpayer’s own testimony the amount of the                  
          expense, the time and place of the use, the business purpose of             
          the use, and, in the case of entertainment, the business                    
          relationship to the taxpayer of each person entertained.  Sec.              
          274(d); sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed.               
          Reg. 46014 (Nov. 6, 1985).  Section 274 requires that expenses be           
          recorded at or near the time when the expense is incurred.  Sec.            
          1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016              
          (Nov. 6, 1985).  Listed property includes passenger automobiles.            
          Sec. 280F(d)(4)(A)(i).                                                      
               We first consider the claimed expenses relating to                     
          petitioner’s employment as a pipefitter.  Petitioner presented no           
          documents to support the claimed business expense deductions.  To           
          the extent that some of the claimed deductions are subject to the           
          strict substantiation requirements of section 274(d), it is clear           
          that petitioner is not entitled to said deductions.  We now                 






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