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of $6,660 to rent the apartment during 1993 and deducted $5,328
as rent expense for other business property.
Petitioner’s claimed deduction of apartment rent must be
disallowed because he failed to provide the substantiation
required by section 274(d).
Taxpayers are permitted to deduct the expenses of a second
residence as travel expenses where the expenses are reasonable
and necessary, incurred while away from home, and incurred in
pursuit of business. See sec. 162(a)(2); Commissioner v.
Flowers, 326 U.S. 465, 470 (1946). Travel expense deductions are
permitted under section 162 only if the substantiation
requirements of section 274(d) are met. This includes deductions
for lodging while away from home. See sec. 274(d)(1); Shea v.
Commissioner, 112 T.C. 183, 188 (1999). The minimum requirements
include substantiating the amount of the expense, the time and
place of the travel or use of the facility or property, and the
business purpose of the expense. See sec. 274(d). A taxpayer
must substantiate each individual expenditure by producing (1)
adequate records or (2) sufficient evidence to corroborate his or
her own statements. See sec. 1.274-5T(c)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
To meet the adequate records standard, the taxpayer must
maintain an account book, diary, log, statement of expenses, or
other similar record in which entries are made at or near the
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