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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,
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