Robert A. Inzano and Martha O. Chavez - Page 5

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          sufficient records to establish deduction amounts.  Sec. 6001;              
          Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965).                     
          Generally, except as provided by section 274(d), when evidence              
          shows that a taxpayer incurred a deductible expense, but the                
          exact amount cannot be determined, the Court may approximate the            
          amount.  Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.               
          1930).  The Court, however, must have some basis upon which an              
          estimate may be made.  Vanicek v. Commissioner, 85 T.C. 731, 742-           
          743 (1985).                                                                 
               A strict substantiation requirement exists under section               
          274(d)(4) for certain items listed under section 280F(d)(4) such            
          as passenger automobiles.  Taxpayers must substantiate by                   
          adequate records the following items in order to claim automobile           
          deductions:  The amount of each automobile expenditure, the                 
          automobile’s business and total usage, the date of the                      
          automobile's use, and the automobile's business purpose.  Sec.              
          274(d); secs. 1.274-5T(b)(6), 1.274-5T(c)(1), Temporary Income              
          Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).                               
               To substantiate a deduction by means of adequate records, a            
          taxpayer must maintain an account book, diary, log, statement of            
          expense, trip sheets, and/or other documentary evidence which, in           
          combination, are sufficient to establish each element of                    
          expenditure or use.  Sec. 1.274-5T(c)(2)(i), Temporary Income Tax           
          Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).  Section 274(d) is an             





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