Sherif S. Abdelhak a.k.a. Samuel A. Abel - Page 13

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               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, * * * (C) the business purpose of                
               the expense or other item, * * *                                       
               The requirements of section 274(d) are designed to ensure              
          taxpayers maintain records and documentation sufficient to                  
          substantiate each expense claimed as a deduction.  See Vanicek v.           
          Commissioner, 85 T.C. 731, 742-743 (1985).  Without business                
          records or other proof to substantiate that those expenses were             
          incurred for business purposes, a taxpayer is not entitled to               
          such deductions.  Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.             
               Petitioner has presented no evidence concerning any rent               
          payments paid by GTG for 1999.  Thus, without any evidence to               
          substantiate the claimed expenses, we find that petitioner is not           
          entitled to any rent expense deduction in excess of the $2,850              
          allowed by respondent.                                                      
               With respect to the travel and entertainment expenses for              
          both 1999 and 2000, petitioner’s evidence consisted of financial            
          records in the form of copied receipts, bills, credit card                  
          statements, and a single expense report from a GTG employee.                
          Petitioner did not offer any testimony as to the business purpose           
          of any of the expenses noted in the financial records.  For                 
          example, while the expense report vaguely listed several costs,             






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