Randolph John Beale - Page 16




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            so, it follows that the mileage expenses for each year are                                 
            nondeductible commuting expenses.                                                          
                  Travel, Meals, and Entertainment                                                     
                  For 1992 and 1993, petitioner claims $120 and $180,                                  
            respectively, for travel expenses, and $640 and $960,                                      
            respectively, for meals and entertainment expenses.  For 1994 and                          
            1995, petitioner claims $425 and $300, respectively, for meals                             
            and entertainment expenses.  Respondent disallowed all of                                  
            petitioner's claimed expenses.                                                             
                  A taxpayer is required under section 274(d) to substantiate                          
            travel, meals, and entertainment expenses by either adequate                               
            records or sufficient evidence corroborating the taxpayer's own                            
            statement as to:  (1) The amount of the expense, (2) the time and                          
            place the expense was incurred, (3) the business purpose of the                            
            expense, and (4) the business relationship to the taxpayer of                              
            each expense incurred.  In the absence of evidence meeting these                           
            strict substantiation requirements, deductions for travel, meals,                          
            and entertainment expenses are not allowed.  See Whalley v.                                
            Commissioner, T.C. Memo. 1996-533; sec. 1.274-5T(b)(4), Temporary                          
            Income Tax Regs., 50 Fed. Reg. 46015 (Nov. 6, 1985).                                       
                  Other than his oral testimony, petitioner did not provide                            
            substantiation of his expenses for travel, meals, and                                      
            entertainment.  Accordingly, petitioner has failed to meet the                             








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