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Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
Petitioner submitted a copy of his business day calendar for
1995. The calendar was written in various inks and records the
names of the clients and employees that petitioner had lunch or
dinner with on each specific day and the dates on which he
traveled. We find that this record was made contemporaneously
during the time the expenses were incurred. The day calendar,
along with petitioner's detailed memoranda explaining the
circumstances of the meals and entertainment and travel expenses,
and copies of the receipts and credit card statements provide
satisfactory evidence of the time and place of the expenses and
that they had a business purpose. We find that the requirements
of section 274(d) are satisfied.
However, of the total amount disallowed by respondent for
these deductions, $642.20 of meals and entertainment expenses and
$1,516.40 of travel expenses, which had been charged on a credit
card in 1994, were deducted by petitioner in 1995, the year in
which petitioner paid the credit card bill. We have previously
held that for cash-basis taxpayers, the "use of a credit card for
an otherwise deductible expense qualifies as a payment in the
year the credit card charge is made, regardless of when the
issuer is repaid". Schroeder v. Commissioner, T.C. Memo. 1986-
583; see also Goldman v. Commissioner, T.C. Memo. 1990-8.
Therefore, the payments made in 1995 for expenses charged in 1994
are not properly deductible in 1995. Accordingly, we sustain
respondent's disallowance of meals and entertainment expense to
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