Carlton H. Perry - Page 17

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          discussed during any such meals.  Based on the instant record, we           
          find that petitioner has failed to establish that the meal expen-           
          ses incurred during 1989 were ordinary and necessary expenses               
          that were incurred in connection with his rental real estate                
          activities.                                                                 
               Petitioner also failed to establish that he satisfied the              
          substantiation requirements of section 274(d).10  A taxpayer may            
          satisfy the substantiation requirements of section 274(d) by                
          adequate records or by sufficient evidence corroborating his or             
          her own statement.  Sec. 1.274-5(c)(1), Income Tax Regs.  To meet           
          the adequate records requirements of section 1.274-5(c)(1),                 
          Income Tax Regs., a taxpayer must keep an account book, diary, or           
          similar document that records information required by section               


          10  Sec. 274(d) provides in pertinent part:                                 
                (d)  SUBSTANTIATION REQUIRED.--No deduction or credit                 
          shall be allowed--                                                          
                        *     *     *     *     *     *     *                         
                   (2) for any item with respect to an activity which is              
             of a type generally considered to constitute entertainment,              
             amusement, or recreation, or with respect to a facility                  
             used in connection with such an activity,                                
                        *     *     *     *     *     *     *                         
             unless the taxpayer substantiates by adequate records or by              
             sufficient evidence corroborating the taxpayer's own state-              
             ment (A) the amount of such expense or other item, (B) the               
             time and place of the * * * entertainment, amusement, re-                
             creation, or use of the facility or property, * * * (C) the              
             business purpose of the expense or other item, and (D) the               
             business relationship to the taxpayer of persons enter-                  
             tained * * *.                                                            



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