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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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