- 14 - into evidence copies of receipts for food and gasoline totaling $232.77 and a copy of an airline ticket in the amount of $318. Mr. Bradley testified that he incurred the food and gasoline expenses in an attempt to generate interest in the property by showing it to a friend from Houston and holding a picnic for local residents. He testified that the airline ticket was purchased to meet with a former business partner in Chicago to discuss developing the land as a low-income housing project. Since the foregoing expenses are for travel and entertainment they must, in addition to meeting the requirements of sections 162 or 212, be substantiated in accordance with the requirements of section 274(d). Since petitioners have not substantiated the business purpose of the foregoing expenditures with a written explanation, see sec. 1.274-5T(c)(2)(ii)(B), Temporary Income Tax Regs., 50 Fed. Reg. 46018 (Nov. 6, 1985), or corroborated Mr. Bradley's statements with direct or circumstantial evidence of the time, place, or business purpose of the expenditures, see sec. 1.274-5T(c)(3)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46020-46021 (Nov. 6, 1985), we find the receipts and Mr. Bradley's testimony insufficient for purposes of section 274(d) substantiation and therefore sustain respondent's determination disallowing the auto and travel expenses. With respect to the disallowance of a $1,500 management fee claimed on Schedule E for the Mississippi land, petitioners offered a copy of a check made out to "DECA Corp." as payee inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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