- 15 - and Los Angeles. In 1993, petitioner contends that Faye Oatis and Linda Klyce traveled to San Diego and Yuma. Petitioner has stipulated that Special O's claimed travel expenses for the years at issue were paid from the personal funds of petitioner or her sisters. Petitioner has failed to establish that any of the claimed travel expenses were reimbursed by Special O. A corporation is not entitled to deduct unreimbursed shareholder expenses. See Lang Chevrolet Co. v. Commissioner, T.C. Memo. 1967-212. Additionally, both Special O and petitioner have failed to provide this Court with either adequate records or sufficient evidence corroborating the claimed travel deductions. Taxpayers must substantiate any deductions claimed. See Hradesky v. Commissioner, 65 T.C. at 90. Section 162(a) allows a taxpayer to deduct "all the ordinary and necessary expenses paid or incurred * * * in carrying on any trade or business". Section 274(d) requires strict substantiation of certain expenses including those incurred with respect to meals, travel, and entertainment. We hold that Special O is not entitled to claim travel expenses in the amounts of $740.81, $2,497, and $1,529 for the 1991, 1992, and 1993 tax years, respectively. Respondent is sustained on this issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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