Jung K. Yoon and Hee S. Yoon - Page 30

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          the taxpayer must meet the specific substantiation requirements             
          of section 274, including the date, time, place, amount, and                
          business purpose of the expense as well as the business                     
          relationship of those entertained by the taxpayer.  Meridian Wood           
          Products Co. v. United States, 725 F.2d 1183, 1188 (9th Cir.                
          1984).  Section 274 precludes our making an estimate, under Cohan           
          v. Commissioner, 39 F.2d 540 (2d Cir. 1930), with respect to                
          travel and entertainment expenses.  See, e.g., Meridian Wood                
          Products Co. v. United States, supra at 1188-1190.  Even if                 
          section 274 were not applicable, there is insufficient evidence             
          here to support an estimate of petitioners' claimed travel and              
          entertainment expenses.  There is also insufficient evidence to             
          support an estimate under Cohan v. Commissioner, supra, for the             
          remaining claimed deductions that fall outside of the                       
          substantiation requirements of section 274, such as business                
          repair expenses.                                                            
               Petitioners have not indicated which expenditures have                 
          already been deducted on JKY's 1990 and 1991 returns.  From the             
          evidence before us, we cannot be certain that any of the claimed            
          expenditures were actually for business purposes.  Yoon did not             
          testify as to the purpose of the expenditures.  Also, from his              
          testimony, it appears that Caufield, not Yoon, classified most of           
          the expenditures on the schedules.  We have been provided only              
          with the amount of the alleged charges and the name of the place            
          where the credit purchase was allegedly made.  For the foregoing            




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