- 244 - No attempt has been made to show that claimed travel and entertainment expenses in any amounts greater than those allowed by respondent were ordinary and necessary or were expended in furtherance of CTC's business, rather than in furtherance of Diesel Power's business or the business of other entities in which petitioner was involved. Instead, petitioner ignores the existence of any other entities on whose behalf he conducted business and merely concludes that an expense was CTC related if it was treated that way on CTC's books or by his tax return preparers. None of petitioner's bookkeepers or return preparers testified that they were present when any expense was incurred; rather, petitioner simply directed how an expense was to be treated on CTC's books. Accordingly, their testimony does nothing to substantiate the business nature of travel and entertainment amounts reflected on either CTC's books or petitioner's tax returns. See Anderson v. Commissioner, T.C. Memo. 1976-28 (testimony of bookkeeper who was not present when expenses were incurred could not substantiate nature of claimed travel and entertainment expenses). In addition to the requirements that expenses be ordinary and necessary as well as in furtherance of taxpayer's business, section 274(d) imposes stringent substantiation criteria. Section 274(d) prohibits a deduction for travel and entertainment expenses unless the taxpayer substantiates by adequate records orPage: Previous 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 253 Next
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