Jordon Jay Fingar - Page 15

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          dates of departure and return for each trip, and the number of              
          days spent on business, (3) the place of travel, and (4) the                
          business benefit derived by the taxpayer for each trip.  Sec.               
          1.274-5(b)(2), Income Tax Regs.                                             
               At trial, petitioner's testimony regarding his travel, meal,           
          and entertainment expenses was vague and in many instances                  
          incoherent.  Although petitioner submitted various receipts and a           
          personal diary for each tax year establishing that he incurred              
          expenses, these documents fail to establish the business purpose            
          and business relationship of these expenses.  Accordingly,                  
          petitioner has failed to meet the strict substantiation                     
          requirements of section 274(d), and we, therefore, sustain                  
          respondent's determination for the taxable years in issue.                  
          Issue 3.  Home Office Deductions                                            
               Respondent determined that petitioner is not entitled to a             
          home office deduction for the taxable years in issue.  Petitioner           
          asserts that during 1979 his home office was used for many                  
          meetings "with the bank people, and with Greenbaum and Dickey,              
          plotting our escape from our respective firms."  Similarly, in              
          1980, petitioner asserts that he used his home office to meet               
          with clients from Robinson and Silverman and to wind down his old           
          business.                                                                   
               Section 280A generally prohibits the deduction of otherwise            
          allowable expenses with respect to the use of an individual                 
          taxpayer's home.  Section 280A(c)(1) provides a narrow exception            




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