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Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
46016-46017 (Nov. 6, 1985).
The elements that a taxpayer must prove with respect to any
listed property are: (1)(a) The amount of each separate expendi-
ture with respect to such property and (b) the amount of each
business use based on the appropriate measure, e.g., mileage for
automobiles, of such property; (2) the time, i.e., the date of
the expenditure or use with respect to any such property; and
(3) the business purpose for an expenditure or use with respect
to such property. Sec. 1.274-5T(b)(6), Temporary Income Tax
Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
The elements that a taxpayer must prove with respect to an
expenditure for traveling away from home on business, including
expenditures relating to the use of such taxpayer’s automobile,
and for meals, are: (1) The amount of each such expenditure for
traveling away from home, except that the daily cost of the
traveler’s own breakfast, lunch, and dinner may be aggregated;
(2) the time of each such expenditure, i.e., the dates of depar-
ture and return for each trip away from home and the number of
days away from home spent on business; (3) the place of each such
expenditure, i.e., the destination or locality of travel, de-
scribed by name of city or town or other similar designation; and
(4) the business purpose of each such expenditure, i.e., the
business reason for the travel or the nature of the business
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