Susan J. Bokhari O'Neil - Page 5

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          however, that no deductions shall be allowed:  (1) For any                  
          traveling expense, including meals and lodging while away from              
          home, (2) for any item with respect to an activity which is of a            
          type generally considered to constitute entertainment, amusement,           
          or recreation, (3) for any expense for gifts, or (4) with respect           
          to any "listed property" as defined in section 280F(d)(4), unless           
          substantiated in accordance with the strict requirements of                 
          section 274(d) and the regulations promulgated thereunder.                  
          Included in the items defined as listed property in section                 
          280F(d)(4) is any passenger automobile.  Sec. 280F(d)(4)(A)(i).             
               To substantiate a deduction under section 274(d), a taxpayer           
          must maintain adequate records or present other corroborative               
          evidence to show, among other things, the business purpose and              
          business relationship of the expense.  Sec. 1.274-5T(b),                    
          Temporary Income Tax Regs., 50 Fed. Reg. 46014-46016 (Nov. 6,               
          1985).                                                                      
               In order to substantiate a deduction by means of adequate              
          records, a taxpayer generally must maintain a diary, a log, or a            
          similar record, and documentary evidence, which, in combination,            
          are sufficient to establish each element of each expenditure or             
          use, including business purpose and relationship.  Sec. 1.274-              
          5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017                 
          (Nov. 6, 1985).                                                             
               Although petitioner produced various receipts and charts in            
          support of her deductions for unreimbursed employee business                





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