Barry D. and Suzanne B. Whalley - Page 10

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          5,200 miles7 driven by Mrs. Whalley during 1991 and 1992,                   
          respectively, from home to professional meetings and conferences.           
               Taxpayers may deduct expenses incurred while traveling away            
          from home if the trip is primarily to obtain education that has             
          the requisite relation to the taxpayer's business.  Sec. 1.162-             
          5(e)(1), Income Tax Regs.  Thus, travel expenses incurred to                
          attend a seminar or continuing education course may be                      
          deductible.  Sec. 1.162-5(e)(2), Income Tax Regs.  To deduct                
          expenses incurred for travel, meals, and lodging while away from            
          home on job-related education, a taxpayer must satisfy the                  
          stringent substantiation requirements of section 274(d) and the             
          regulations thereunder.  A taxpayer must substantiate each                  
          element of an expenditure incurred for travel, meals, and lodging           
          while away from home either by adequate records or by sufficient            
          evidence corroborating his or her own statement.  Sec. 1.274-               
          5T(c), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6,              
          1985).                                                                      
               For travel expenses, including meals and lodging, a taxpayer           
          must substantiate:  (1) The amount of such expense, (2) the time            
          and place such expense was incurred, and (3) the business purpose           
          for which such expense was incurred.  Sec. 1.274-5T(b)(2),                  
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              
          Section 274(d) specifically bars a taxpayer from claiming a                 

          7    As we previously indicated, the standard mileage allowances            
          for 1991 and 1992 were 27.5 and 28 cents per mile, respectively.            
          Rev. Proc. 90-59, 1990-2 C.B. 644; Rev. Proc. 91-67, 1991-2 C.B.            
          887.                                                                        



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