- 18 - 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 mannerPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011