Raymond Strong - Page 18

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          Sanford v. Commissioner, 50 T.C. 823, 827-828 (1968), affd. 412             
          F.2d 201 (2d Cir. 1969).                                                    
               We consider first petitioner’s claimed business meals                  
          expenses, then his other claimed business expenses.                         
          A. Business Meals Expenses                                                  
               The parties agree that petitioner’s claimed business meals             
          expenses are not deductible if they fail to meet the requirements           
          of section 274(d).                                                          
               Petitioner’s right to deduct his claimed meals and                     
          entertainment expenses turns on (1) whether the diary and the               
          stubs constitute adequate records for purposes of section 1.274-            
          5T(c)(2), Temporary Income Tax Regs., and if not, then (2)                  
          whether sufficient evidence to corroborate petitioner’s own                 
          statements has been presented.  Sec. 1.274-5T(c)(3), Temporary              
          Income Tax Regs.                                                            
               (1) Adequate Records                                                   
               Under section 1.274-5T(c)(2)(i), Temporary Income Tax Regs.,           
          in order to meet the "adequate records" requirement, a taxpayer             
          is to maintain an account book, diary, statement of expenses, or            
          similar record and documentary evidence (such as receipts, paid             
          bills, or similar evidence) which, when combined, establish each            
          element of the expense that section 274(d) requires to be                   
          established.  The account book, diary, statement of expense, or             
          similar record must be prepared or maintained in such a manner              






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