James L. Christian - Page 6




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          time of the expenditure.  See sec. 1.274-5T(c)(2), Temporary                
          Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).  In                    
          addition, the taxpayer must supply documentary evidence such as             
          receipts or paid bills.  See sec. 1.274-5T(c)(2)(iii), Temporary            
          Income Tax Regs., 50 Fed. Reg. 46019 (Nov. 6, 1985).  A taxpayer            
          who is unable to meet the adequate records standard may be able             
          to substantiate travel expenses with his own statements                     
          containing specific details of each element, in conjunction with            
          other corroborative evidence of each element.  See sec. 1.274-              
          5T(c)(3), Temporary Income Tax Regs., 50 Fed. Reg. 46020 (Nov. 6,           
          1985).                                                                      
               Although the parties agreed at trial that petitioner paid              
          rent for the apartment in Orange, California, petitioner failed             
          to substantiate the rent payments as travel expenses related to             
          his business.  He failed to provide any records indicating the              
          dates of travel or the specific purpose for each trip.  In                  
          failing to provide an account book, diary, log, or any other                
          specific record of his travel and expenditures, petitioner failed           
          to meet the adequate records standard.                                      
               Petitioner also flunked the alternative test.  His testimony           
          failed to set forth with any particularity the dates and times of           
          his travel or the specific business purpose for each trip.  Nor             
          did petitioner produce any witnesses or any other evidence to               
          corroborate when and how often he used the apartment and that               






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