Kin L. Velinsky - Page 19

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          expense; and (4) the business relationship to the taxpayer of               
          persons entertained.  The regulations make it clear that section            
          274(d) supersedes the doctrine of Cohan v. Commissioner, supra,             
          and that a deduction for travel and entertainment must be                   
          supported by more than approximations or unsupported testimony of           
          a taxpayer.  Sec. 1.274-5(a), Income Tax Regs.  Under section               
          274(d), every expenditure claimed as a deduction must be                    
          substantiated by the taxpayer by either adequate records or other           
          sufficient evidence, and his or her failure to do so will cause             
          such expenditures to be disallowed in full.  See Sanford v.                 
          Commissioner, 50 T.C. 823, 828-829 (1968), affd. per curiam 412             
          F.2d 201 (2d Cir. 1969).                                                    
               Petitioner offered into evidence copies of several receipts            
          from various restaurants, as well as tickets to sporting events             
          and theaters.  Petitioner also offered into evidence various                
          canceled checks to evidence travel expenses.  However, these                
          items were not shown to be related to Mr. Velinsky's business,              
          except by petitioner's testimony that she never saw her husband             
          retain receipts for nonbusiness meals and entertainment, and that           
          her husband often took business trips.  There was no record of              
          the business purpose of the travel or claimed entertainment.  The           
          record does not show the persons present at any meetings, and, in           
          most cases, the time and place of the meetings or entertainment             
          are not shown.  We, therefore (under section 274(d)) sustain                






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