- 10 - regulations that allow a taxpayer to reconstruct his records, citing section 1.274-5T(c)(4) and (5), Temporary Income Tax Regs., 50 Fed. Reg. 46006, 46021-46022 (Nov. 6, 1985). The Court notes, however, that petitioner's records were lost, through theft, for only a portion of the year at issue, and only the airplane FAA log and some of the receipts relating to the airplane were so lost. Petitioner suffered no such loss of records with respect to the other expenses at issue, nor were such records lost as to the airplane for the remainder of 1992. The Court, therefore, considers whether the records petitioner submitted that were not lost and, therefore, were not reconstructed pass muster under section 274(d). The records submitted do not satisfy the record-keeping requirements of section 274(d) for several reasons. Most notably, petitioner did not maintain a contemporaneous record of the expenses, at or near the time they were incurred. Perhaps the most important element of the record-keeping requirement is the contemporaneous maintenance of a log, chronicling each event in which an expense is incurred and corroborating that expense with receipts or other documents evidencing that the expense was incurred. The documentation submitted by petitioner fails to satisfy this requisite. Although petitioner submitted numerous cash and credit card receipts, most of these receipts bear no information tying the receipt to an event or an expense. The reconstructedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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