Eli and Karen Yecheskel - Page 6

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          to provide that no deduction shall be allowed with respect to any            
          listed property as defined in section 280F(d)(4)--                           

               unless the taxpayer substantiates by adequate records or by             
               sufficient evidence corroborating the taxpayer's own                    
               statement (A) the amount of such expense or other item, (B)             
               the time and place of the travel * * *, (C) the business                
               purpose of the expense or other item, and (D) the business              
               relationship to the taxpayer of persons entertained, using              
               the facility or property, or receiving the gift. * * *                  

               Listed property, as defined in section 280F(d)(4), includes             
          any passenger automobile or any other property used as a means of            
          transportation.  In addition, section 274(d)(1) requires the same            
          substantiation for any deduction claimed "under section 162 or               
          212 for any traveling expense".                                              
               The elements required to substantiate a claimed                         
          transportation expense deduction under section 274(d) include the            
          amount of each separate expenditure with respect to an item of               
          listed property, such as the cost of acquisition of the listed               
          property.  Sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50               
          Fed. Reg. 46016 (Nov. 6, 1985).  Although petitioner did not                 
          maintain records that would satisfy the substantiation                       
          requirements of section 274(d) for expenses incurred in                      
          connection with the use of the automobile, petitioners did                   
          satisfy the substantiation requirements for the cost of the                  
          automobile by offering into evidence the original canceled check             
          issued for payment of the vehicle in the amount of $15,313.  To              





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