- 16 - 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 thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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