- 19 - connection with a profit-motivated trade or business.11 Further, respondent argued, petitioner's participation as a member of the EPC was not regular, continuous, and with the primary purpose of making a profit as required by section 162. Finally, respondent argued, petitioner failed to substantiate the amount of his travel expenses incurred away from home, as required by section 274(d). The expenses petitioner claimed were travel expenses incurred with respect to trips taken by petitioner in connection with his duties as spokesperson for the EPC. Petitioner introduced into evidence a computer-generated printout, which he had prepared in anticipation of trial, of the amounts and descriptions of his claimed expenses. However, petitioner failed to produce any receipts or other similar corroborative evidence to substantiate the various amounts, times, places, or business purposes of his claimed expenses. In short, petitioner failed to introduce any documentary evidence sufficient to support his claimed expenses incurred in connection with his duties as a member of the EPC. The Court finds that petitioner's records are insufficient to satisfy the stringent substantiation requirements of section 274(d). In the case of travel expenses, specifically including 11 Petitioner admitted at trial that his position with the EPC was a volunteer position.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011