- 18 - receipt for a camper top and running boards, among other things, for her truck. In total, the amounts paid to American Appliance and the amounts paid for improvements to the truck equal the amount disallowed by respondent--$2,412. Petitioner has failed to prove that any of these disallowed amounts was a necessary expense for a business, rather than personal, purpose. Therefore, petitioner failed to sustain her entitlement to a deduction for supplies in any amount greater than $2,174. Accordingly, we sustain respondent's determination. F. Travel and Entertainment Expenses Petitioner claimed a deduction of $446 on her 1985 Federal income tax return for travel and entertainment. Respondent determined that petitioner was not entitled to this deduction. Section 274(d) requires that the taxpayer substantiate by adequate records or by sufficient evidence corroborating her own statement expenses claimed for travel and entertainment by showing (1) the amount of the expense, (2) the time and place of travel or entertainment, (3) the business purpose of the travel or entertainment, and (4) the business relationship to the taxpayer of each person entertained. These four elements must be established for each separate expenditure. Sec. 1.274-5(c)(1), Income Tax Regs. Petitioner presented a schedule showing the breakdown of the $446 deduction claimed -- expenditures in the amount $218, $119,Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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