M. Maureen Polsby - Page 5

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          Heininger, 320 U.S. 467, 475 (1943).  However, no deduction shall           
          be allowed for personal, living, or family expenses.  Sec. 262.             
               Section 274(d) imposes stringent substantiation requirements           
          for the deduction of travel expenses (including meals and lodging           
          while away from home), entertainment expenses, gift expenses, and           
          expenses of certain listed property defined under section                   
          280F(d)(4) such as an automobile.  Taxpayers must substantiate by           
          adequate records certain items in order to claim deductions, such           
          as the amount and place of each separate expenditure, the                   
          property's business and total usage, the date of the expenditure            
          or use, and the business purpose for an expenditure or use.  Sec.           
          274(d); sec. 1.274-5T(b), 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).                                   
               If an expense item comes within the requirements of section            
          274(d), this Court cannot rely on Cohan v. Commissioner, supra,             
          to estimate the taxpayer's expenses with respect to that item.              
          Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per                 
          curiam 412 F.2d 201 (2d Cir. 1969).                                         





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