Steve and Lura Pasharikoff - Page 4

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          the absence of corroborating evidence, we are not required to               
          accept the self-serving and unverified testimony of a taxpayer.             
          Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski             
          v. Commissioner, 87 T.C. 74, 77 (1986).                                     
               Moreover, section 274(d) provides that no deduction is                 
          allowable under section 162 or 212 for any traveling expenses,              
          including meals and lodging while away from home, or with respect           
          to any listed property, defined in section 280F(d)(4) to include            
          property used as a means of transportation, unless the taxpayer             
          complies with strict substantiation rules.  Sec. 274(d)(1), (4).            
          In particular, the taxpayer must substantiate the amount, time,             
          place, and business purpose of the expenses by adequate records             
          or by sufficient evidence corroborating his own statement.  Sec.            
          274(d); sec. 1.274-5T(b)(2), (c), Temporary Income Tax Regs., 50            
          Fed. Reg. 46014, 46016 (Nov. 6, 1985).                                      
               Based on the limited record in this case, we find that                 
          petitioners have failed to adequately substantiate petitioner's             
          alleged expenses in accordance with the requirements of section             
          274(d).  We therefore hold that petitioners are not entitled to             
          deductions for expenses allegedly paid while petitioner worked in           
          Florida.                                                                    
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          






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