John Edward Kerrigan and Joan Marie Kerrigan - Page 13

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            Travel and Entertainment Expenses                                                          

                  Mrs. Kerrigan claimed a Schedule C deduction for travel and                          
            entertainment expenses in the amount of $16,834.12.  Respondent                            
            allowed a deduction of $177.                                                               
                  Mrs. Kerrigan claimed expenses in 1985 for 259 meals for a                           
            total cost of $6,931.  Petitioners argue that these meals were                             
            consumed during meetings Mrs. Kerrigan had with her business                               
            clients and associates.                                                                    
                  Section 274 disallows deductions for entertainment expenses                          
            unless the taxpayer is able to establish that the item is related                          
            to, or associated with, the active conduct of his or her trade or                          
            business.  Sec. 274(a)(1)(A).  At the same time, section 274(d)                            
            imposes substantiation requirements for these deductions which                             
            are even more exacting than the requirements under section 162                             
            for ordinary and necessary business expense deductions.  A                                 
            taxpayer generally must substantiate each expenditure by                                   
            producing adequate records or sufficient evidence to corroborate                           
            his or her own statements.  Sec. 1.274-5(c)(1), Income Tax Regs.                           
            The "adequate records" standard, in turn, requires that a                                  
            taxpayer maintain an account book, which contains contemporaneous                          
            entries which clearly indicates the requisite business purpose.                            
            Sec. 1.274-5(c)(2)(i) and (ii), Income Tax Regs.  In addition, a                           
            taxpayer must generally supply documentary evidence, such as                               
            receipts or paid bills.  Sec. 1.274-5(c)(2)(iii), Income Tax                               
            Regs.  Alternatively, taxpayers who are unable to satisfy the                              



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