Roger L. and Geraldine Williams - Page 8

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               Section 162(a) authorizes deductions for ordinary and                  
          necessary expenses paid during the taxable year in carrying on a            
          trade or business.  However, section 262 generally precludes                
          deductions for personal expenses.  Thus, expenses incurred by a             
          taxpayer in commuting between his or her home and place of                  
          business are personal and nondeductible.  Commissioner v.                   
          Flowers, 326 U.S. 465, 473-474 (1946); secs. 1.162-2(e), 1.262-             
          1(b)(5), Income Tax Regs.2                                                  
               Moreover, section 274(d)(4) provides that no deduction is              
          allowable with respect to listed property, as defined in section            
          280F(d)(4), unless the deduction is substantiated in accordance             
          with the strict substantiation requirements of section 274(d) and           
          the regulations promulgated thereunder.  Included in the                    
          definition of listed property in section 280F(d)(4) is any                  
          passenger automobile.  Sec. 280F(d)(4)(A)(i).                               
               In order to substantiate a deduction attributable to listed            
          property, a taxpayer must maintain adequate records or present              
          corroborative evidence to show: (A) The amount of the expense or            
          use, (B) the time and place of the expenditure or use of the                
          listed property, and (C) the business purpose for the expenditure           
          or use.  Sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed.           
          Reg. 46016 (Nov. 6, 1985).                                                  

          2  In contrast, expenses incurred in traveling between two                  
          places of business are deductible.  Heuer v. Commissioner, 32               
          T.C. 947, 953 (1959), affd. per curiam 283 F.2d 865 (5th Cir.               
          1960).                                                                      




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