Joseph Baldwin Campbell - Page 18

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            United States, 245 F.2d 559, 560 (5th Cir. 1957).  In estimating                             
            the amount allowable, the Court bears heavily against the                                    
            taxpayer whose inexactitude is of his or her own making.  Cohan                              
            v. Commissioner, supra at 544.                                                               
                  The deduction for travel expenses away from home, including                            
            meals and lodging, under section 162(a)(2), is conditioned on                                
            such expenses being substantiated by "adequate records" or by                                
            sufficient evidence corroborating the claimed expenses pursuant                              
            to section 274(d).  Sec. 1.274-5(a)(1), Income Tax Regs.  To meet                            
            the adequate records requirements of section 274(d), a taxpayer                              
            "shall maintain an account book, diary, statement of expense or                              
            similar record * * * and documentary evidence * * * which, in                                
            combination, are sufficient to establish each element of an                                  
            expenditure".  Sec. 1.274-5(c)(2)(i), Income Tax Regs. (emphasis                             
            added).  The elements to be proven with respect to each traveling                            
            expense are the amount, time, place, and business purpose of the                             
            travel.  Sec. 1.274-5(b)(2), Income Tax Regs.  The substantiation                            
            requirements of section 274(d) are designed to encourage                                     
            taxpayers to maintain records, together with documentary evidence                            
            substantiating each element of the expense sought to be deducted.                            
            Sec. 1.274-5(c)(1), Income Tax Regs.                                                         
                  Respondent argued that petitioner's position with the EPC                              
            was purely a volunteer position and, therefore, was not in                                   

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