Pennel Phlander Irwin - Page 17

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            expenses.  Keating v. Commissioner, T.C. Memo. 1995-101; sec.                                 
            1.274-5(a), Income Tax Regs.                                                                  
                  Petitioner claims deductions with respect to:  (1) Trips to                             
            Reno, Nevada, in 1990 and 1991; (2) a trip to Michigan in 1990,                               
            including expenses for his daughter, employed as a "research                                  
            assistant"; (3) trips to Lake Tahoe, Nevada, in 1990 and 1992;                                
            and (4) a trip to Pacific Grove, California, in 1991.  In a                                   
            misguided attempt to protect the names of purported writing                                   
            sources, petitioner has refused to provide sufficient evidence,                               
            such as contemporaneously prepared logs or diaries, from which we                             
            could ascertain the business purpose of his travel.  Sec. 1.274-                              
            5T(c)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6,                             
            1985).  Furthermore, we are convinced that some of petitioner's                               
            expenditures, such as the costs of travel to Michigan with his                                
            daughter to attend petitioner's mother's funeral and conduct                                  
            "research" for Great Woods Poppy, were undoubtedly personal in                                
            nature.  As petitioner has failed to meet the substantiation                                  
            requirements of section 274(d), we sustain respondent's denial of                             
            all travel expenses.                                                                          
                       (G)  Research                                                                     
                  Petitioner introduced canceled checks, attributable to a                                
            variety of expenditures, purportedly related to his literary                                  
            research.  While petitioner lists the amounts of expenditures, he                             
            failed to present any detailed evidence concerning the specific                               
            nature of each expenditure.  Many of these expenditures are                                   




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