Rick and Ruth Baime Richards - Page 15

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               Taxpayers may deduct travel expenses incurred while away               
          from home in pursuit of a trade or business.  See sec. 162(a)(2).           
          Traveling expenses are governed by the strict substantiation                
          requirements of section 274(d).  Under section 274(d),                      
          petitioners must substantiate by adequate records or by                     
          sufficient evidence corroborating their own statement:  (1) The             
          amount of the expense; (2) the time of travel; (3) the place of             
          travel; and (4) the business purpose of the expense.  See sec.              
          274(d); sec. 1.274-5T(b)(2), (c)(1), Temporary Income Tax Regs.,            
          50 Fed. Reg. 46014 (Nov. 6, 1985).  If petitioners fail to meet             
          the provisions of section 274(d), we cannot employ the principles           
          of Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), to estimate           
          petitioners’ travel expenses.  See Keating v. Commissioner, T.C.            
          Memo. 1995-101; sec. 1.274-5(a), Income Tax Regs.                           
               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.  See sec. 1.274-5T(c)(2)(i), Temporary Income           
          Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).                               
               Petitioners did not provide any records that would                     
          substantiate when and where they traveled and the business                  
          purpose of each trip.  The receipts that petitioners submitted do           
          not satisfy the provisions of section 274(d).  Petitioners have             

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