Charles and Beatrice M. Reynolds - Page 34




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         employment.  See Bryant v. Commissioner, T.C. Memo. 1993-597,                
         affd. 39 F.3d 1168 (3d Cir. 1994).                                           
              Petitioners have not substantiated the business nexus for any           
         of the claimed automobile expenses for driving to or from                    
         petitioner’s law practice, farm, or rental property, or that he              
         incurred auto expenses as a condition of his employment with the             
         IRS.  See Dowell v. United States, 522 F.2d 708, 714 (5th Cir.               
         1975) (each and every element of each and every expenditure must             
         be substantiated).  We find, therefore, that petitioner’s                    
         testimony and the monthly and yearly mileage reconstructions do              
         not meet the requirements of section 274(d).                                 
              B.   Travel and Meals and Entertainment Expenses                        
                   1.   Law Practice                                                  
              Petitioners claimed meals and entertainment expenses on                 
         Schedule C for 1993 of $559, and travel and meals and                        
         entertainment expenses of $151 for 1994.  Petitioners provided no            
         acceptable substantiation for entertainment expenses for either              
         year.                                                                        
              Of the $559 claimed for meals and entertainment expenses for            
         1993, $367.34 was expended for a “family get-together” in 1993 on            
         the occasion of the death of Mrs. Reynolds’ mother in Virginia.              
         Petitioner testified that “I went as an individual who was there             
         as a mourner”, but a legal matter arose as to how to handle the              
         estate, which petitioner described as “indigent”.  Petitioner                





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