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Corporation, CDC, and various Florida real estate projects
involving other corporate entities in the later years. The more
frequently named individuals who fall into this category include
Mr. and Mrs. Khalatbari, Dr. Fallah, Olin Atkins, Hossein
Zanganeh, and Bill McCabe, as well as representatives of various
U.S. manufacturers who dealt with both Diesel Power and CTC.
Petitioner acknowledged that the diaries only generally
reflect his travel and entertainment expenses. The diaries do
not reflect sundry travel expenses or minimal amounts. Most of
the expenditures reflected in the diaries are for amounts in
excess of $25; many of the expenses shown for hotel bills,
dinners, and entertaining are for hundreds of dollars, with no
supporting documentation as to either the amount or the business
purpose.
Alternatively, the substantiation requirements of section
274(d) can be satisfied by a taxpayer's oral or written statement
supported by "other corroborative evidence". Other corroborative
evidence can take two forms: (1) Oral or written testimony of
third persons with actual knowledge of the expenditures or (2)
documentary evidence subject to the same requirements imposed
under the "adequate records" test. Sec. 1.274-5(c)(3), Income
Tax Regs. In our opinion petitioner has not complied with this
alternative substantiation method. Several persons named in his
diaries did testify at trial, but none corroborated any meeting
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