Thomas M. and Dolores F. Gomez - Page 8

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                    constitute entertainment, amusement, or                            
                    recreation, or with respect to a facility used in                  
                    connection with such an activity,                                  
                              *   *   *   *   *   *   *                                
               unless the taxpayer substantiates by adequate records                   
               or by sufficient evidence corroborating the taxpayer's                  
               own statement (A) the amount of such expense or other                   
               item, (B) the time and place of the travel,                             
               entertainment, amusement, recreation, or use of the                     
               facility or property, or the date and description of                    
               the gift, (C) the business purpose of the expense or                    
               other item, and (D) the business relationship to the                    
               taxpayer of persons entertained, using the facility or                  
               property, or receiving the gift.  * * *                                 
               The expenses petitioner deducted as unreimbursed employee               
          business expenses consisted of meals and entertainment, travel,              
          lodging, and telephone expenses.  For petitioner to prevail, he              
          had to satisfy the substantiation requirements of section 274                
          with respect to all expenses claimed except the telephone                    
          expense.  He failed to do so.                                                
               Documentation for some but not all of the unreimbursed                  
          employee business expenses claimed was admitted into evidence in             
          the trial of this case.  During cross-examination regarding the              
          documentation, petitioner admitted that some of the expenses were            
          included on his 1993 travel expense reports and had been                     
          reimbursed.  He also admitted that some of the expenses were                 
          really personal expenses.  As to all of the remaining expenses,              
          petitioner failed to prove (1) the business purpose or nature of             
          the expenses and (2) the reason, if any, why the expenses, even              

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