Robert C. Fors and Lucille Fors - Page 7

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          Meals and Entertainment Expenses                                            
               Petitioner claimed a deduction for meals and entertainment             
          expenses in the amount of $8,240, after accounting for the                  
          section 274(n)(1) 80-percent limitation.  In the statutory notice           
          of deficiency, respondent disallowed $5,804 of the claimed                  
          deduction.  Respondent argues that petitioner has failed to                 
          substantiate his meals and entertainment expenses in excess of              
          the amount allowed in the statutory notice of deficiency.                   
               Section 162(a) allows a deduction for the ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.  Section 274(d) provides that no           
          deduction shall be allowed with respect to any traveling expense,           
          including meals while away from home, or for any entertainment              
          expenses, unless the taxpayer meets strict substantiation                   
          requirements.  Sec. 274(d)(1) and (2).  In particular, the                  
          taxpayer must substantiate by adequate records or by sufficient             
          evidence corroborating the taxpayer's own statement the amount,             
          time, place, and business purpose of the expense.  Sec. 274(d).             
               Petitioner submitted some receipts for the claimed meals and           
          entertainment expenses.  He also submitted copies of his daily              
          planner along with weekly charts on which he listed the amount              
          and purpose of the expenses he allegedly paid during 1992 in the            
          course of his real estate activity.                                         
               Respondent's revenue agent, Marci Coopersmith, examined                
          petitioner's daily planner, weekly charts, and other receipts               




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