Joellen Miller Murata - Page 11

                                               - 11 -                                                  

            substantiated should be recorded at or near the time of that                               
            expenditure or use.  Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income                          
            Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).                                              
                  Thus, under section 274(d), and as with travel expenses, no                          
            deduction may be allowed for expenses incurred for the use of a                            
            passenger automobile on the basis of any approximation or the                              
            unsupported testimony of the taxpayer.  E.g., Golden v.                                    
            Commissioner, T.C. Memo. 1993-602.                                                         
            Research Expenses                                                                          
                  Petitioner claimed a Schedule A deduction for research                               
            expenses in the amount of $4,125, of which respondent has                                  
            conceded $3,443.89.  Of the remaining amount ($681.11), $343.20                            
            relates to petitioner's claim that she is entitled to a deduction                          
            for more mileage than respondent allowed; $108 pertains to                                 
            petitioner's contention that section 274(n) does not pertain to                            
            her meals expenses; and $229.91 pertains to miscellaneous                                  
            expenses.                                                                                  
                  With regard to the mileage expense, petitioner drove from                            
            Rochester, New York, to Portland, Oregon, to attend the Second                             
            International Family Nursing Conference.  Based upon a stipulated                          
            Rand McNally mileage chart, respondent conceded that petitioner                            










Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011