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date of the contribution, and the amount of the contribution.
Sec. 1.170A-13(a)(1), Income Tax Regs. The reliability of a
written record is to be determined based on all the facts and
circumstances of a particular case. Sec. 1.170A-13(a)(2)(i),
Income Tax Regs. Factors indicating that a written record is
reliable include the contemporaneous nature of the writing and
the regularity of the taxpayer's recordkeeping procedure. Id.
Travel expenses incurred by a person while rendering services on
behalf of a charitable organization are not subject to the strict
substantiation requirements of section 274(d). Sec. 274(d);
Francis v. Commissioner, T.C. Memo. 1988-226.
Respondent disallowed certain deductions claimed by
petitioner for unreimbursed travel expenses for the taxable years
1990 and 1991. According to the stipulation of facts, after
concessions, the amount of unreimbursed travel expenses at issue
for 1990 and 1991 are $5,859.94 and $9,400, respectively.
Respondent disallowed these deductions for one or more of the
following reasons: (1) Petitioner failed to substantiate the
deductions; (2) certain expenses were deducted twice; (3) certain
meal expenses are not deductible because they were not associated
with overnight travel; (4) some expenditures were lavish or
extravagant; (5) some expenditures were not necessary; and (6)
section 170(j) disallows the expenses from certain trips
involving personal pleasure, recreation, or vacation. Respondent
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