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Under section 274(d), no deduction may be allowed for
expenses incurred for travel, entertainment, or certain other
expenses, on the basis of any approximation or the unsupported
testimony of the taxpayer. See, e.g., Joly v. Commissioner, T.C.
Memo. 1995-413. Section 274(d) imposes stringent substantiation
requirements to which taxpayers must strictly adhere. Thus,
section 274(d) specifically proscribes deductions for travel or
entertainment expenses in the absence of adequate records or of
sufficient evidence corroborating the taxpayer's own statement.
Id.
Section 274(d)(4) also provides that no deduction is
allowable with respect to listed property, as defined in section
280F(d)(4), unless the deductions are substantiated in accordance
with the strict substantiation requirements of section 274(d) and
the regulations promulgated thereunder. Included in the
definition of listed property in section 280F(d)(4) is any
passenger automobile or any other property used as a means of
transportation. Sec. 280F(d)(4)(A)(i), (ii).
To substantiate a deduction attributable to listed property,
a taxpayer must maintain adequate records or present
corroborative evidence to show the following: (1) The amount of
the expense; (2) the time and place of use of the listed
property; and (3) the business purpose of the use. Sec. 1.274-
5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,
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Last modified: May 25, 2011