Shizuo George Kurata - Page 13

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            establish that the deduction was for an ordinary and necessary                            
            business expense or was expended for the purpose designated on                            
            the 1989 tax return.  The 1989 tax return indicates that                                  
            petitioner claimed the deduction for vehicle expenses, travel                             
            expenses, and meal and/or entertainment expenses.                                         
                  Section 162(a)(2) permits a deduction for traveling                                 
            expenses, including amounts expended for meals and lodging,                               
            incurred by a taxpayer while away from home in the pursuit of a                           
            trade or business.  The taxpayer must demonstrate that the                                
            expenses were (1) reasonable and necessary traveling expenses,                            
            (2) incurred “while away from home”, and (3) incurred in the                              
            pursuit of business.  See, e.g., Commissioner v. Flowers, 326                             
            U.S. 465, 470 (1946).  In addition, section 274(d) imposes strict                         
            substantiation requirements.  Section 274(d) provides that, with                          
            certain inapplicable exceptions, no deduction for traveling                               
            expenses (or similar items) shall be allowed                                              
                  unless the taxpayer substantiates by adequate records                               
                  or by sufficient evidence corroborating the taxpayer's                              
                  own statement (A) the amount of such expense or other                               
                  item, (B) the time and place of the travel,                                         
                  entertainment, amusement, recreation, or use of the                                 
                  facility or property, or the date and description of                                
                  the gift, (C) the business purpose of the expense or                                
                  other item, and (D) the business relationship to the                                
                  taxpayer of persons entertained, using the facility or                              
                  property, or receiving the gift. * * *                                              
                  At trial, petitioner stated that, in 1989, he maintained                            
            “tax homes” in Arlington, Texas, and Everett, Washington, while                           
            working as a contract engineer in California.  Petitioner claims                          

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