- 138 - none of them had independent knowledge pertaining to his underlying claimed expenses for travel and entertainment. By the Court's Order dated October 9, 1992, summaries of the diaries for 1973 (Pet. Exh. 3114), 1974 (Pet. Exh. 3116), 1975 (Pet Exh. 3118), 1976 (Pet. Exh. 3119), 1977 (Pet. Exh. 3120), 1978 (Pet. Exh. 3195), and 1979 (Pet. Exhs. 3202 and 3206), were not received in evidence. Additionally, because there were no diaries for 1980 and 1981, the Court did not receive in evidence petitioner's summaries (Exhs. 3209, 3211, and 3214) of travel and entertainment expenses claimed for those years. Petitioner's diaries do not meet the "adequate records" substantiation requirements necessary to deduct travel and entertainment expenses pursuant to section 274. 1973 Although petitioner claimed a deduction of $98,481.64 on his 1973 tax return for travel and entertainment expenses, only $80,192.81 was recorded in CTC's disbursements journal. Petitioner claimed cash expenses of $17,500, but his travel diary showed no more than $8,154 in cash expenses. Some of these were for personal rather than business expenses. His return preparer estimated petitioner's cash expenses by comparing the number of checks petitioner wrote for cash with the number of days his diary shows he was out of the United States. No allowance was made for any personal travel. Hence, petitioner is not entitledPage: Previous 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 Next
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