- 6 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011