- 11 - Taxpayers generally bear the burden to substantiate claimed meal, entertainment, and travel expenses. Sec. 274(d)(1) and (2); Rule 142(a). Petitioner argues that because he worked solely on commission as a stockbroker, all of his time spent at the Club involved either the solicitation of potential clients or the conduct of business with current clients, and therefore that the $7,000 (after the statutory 2-percent adjustment) claimed as business expenses incurred at the Glen Ridge Country Club should be allowed. Respondent argues that petitioner has adequately substantiated only $9,138 of the total $31,796 claimed expenses. With respect to petitioner's claimed business expenses incurred at the Club, petitioner has failed to offer any credible documentation to support the deduction of these expenses. Petitioner's records from the Club that are in evidence indicate only the general category of expenses petitioner incurred, and petitioner offers no records or other verification relating the specific expenses incurred to specific business-related activity. With respect to petitioner's other claimed expenses, we find the record devoid of any documentation or other basis to support any credible estimate. Cohan v. Commissioner, supra. Petitioner has failed to meet his burden of proving that he is entitled to any of the above claimed expense deductions other than the $9,138 that respondent has allowed.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011