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payments to Rialto Discount Mall. For the months disallowed,
petitioners provided no documentary evidence that the claimed
expenses were paid and provided no other evidence to corroborate
their claim. Therefore, we conclude that petitioners failed to
substantiate that the claimed expenses were paid or incurred.
Thus, petitioners are not entitled to rental expenses in excess
of those allowed by respondent in 1992.
Issue 2. Mileage Expenses
Section 162(a) allows a deduction for all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business, including traveling expenses
while "away from home" in the pursuit of a trade or business. A
deduction for transportation expenses is also allowed for local
travel from one business location to another. Secs. 162(a)(2),
274. Both traveling expenses and transportation expenses are
subject to the substantiation requirements of section 274(d),
which provides in part that
SEC. 274(d). Substantiation Required.--No deduction or
credit shall be allowed--
(1) under section 162 or 212 for any traveling expense
(including meals and lodging while away from home),
* * * * * * *
(4) with respect to any listed property (as defined in
section 280F(d)(4)[3]),
3 Sec. 280F(d)(4)(A)(i) provides that listed property means
(continued...)
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