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directly attributable to such business. The term does not
include nondeductible personal, living, or family expenses.
Section 1.162-17(a), Income Tax Regs. In addition, expenses paid
or incurred for travel, entertainment, and meals are not
deductible unless substantiated by adequate records or
corroborating evidence of (1) the amount of the expense, (2) the
time and place of travel or entertainment, (3) the business
purpose of the expense, and (4) the business relationship to the
taxpayer of the beneficiary of the expense. Section 274(d).
Petitioner submitted various documents purporting to
substantiate his claimed excess expenses. In addition, he
submitted several "summaries" of his expenses.
The documents and summaries submitted by petitioner and the
testimony he presented at the time of trial fail to substantiate
his claimed excess expenses. Indeed, although petitioner
testified that he kept "meticulous" records, he stated that one
of the summaries he prepared from these records was a "probable"
chronology of the travel he undertook on behalf of Con Tex, Inc.
He also admitted that not all of the documents he submitted in
support of his claimed deductions pertained to his work for Con
Tex, Inc.
Furthermore, at least one of the airline itineraries
submitted by petitioner pertains to travel by petitioner's wife,
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Last modified: May 25, 2011