- 7 - Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969). Section 274(d) imposes stringent substantiation requirements for certain deductions, including travel, entertainment, and meal expenses. Jeffers v. Commissioner, T.C. Memo. 1986-285; sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). Thus, section 274(d) specifically proscribes deductions for travel or entertainment expenses in the absence of adequate records or of sufficient evidence corroborating the taxpayer's own statement. See Joseph v. Commissioner, supra. Section 274(d) also applies to business use of certain property such as passenger automobiles. Secs. 274(d)(4), 280F(d)(4)(A)(i). In general, when a taxpayer's records have been lost or destroyed through circumstances beyond his control, he is entitled to substantiate the deductions by reconstructing his expenditures through other credible evidence. At trial, respondent conceded: "The record has shown today that the records--the receipts and invoices that have been presented to the Government have been reconstructed in such a way that they are essentially the same as they would have been, had they not been destroyed". 2. Advertising Petitioner claimed a deduction for advertising expenses in the amount of $830.16. To obtain clients, petitioner was required to advertise her services. Petitioner createdPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011