- 8 - 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, evenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011