Joseph B. Campbell - Page 28




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          business expenses paid and incurred by him * * * broken down into           
          such broad categories as transportation, meals and lodging while            
          away from home overnight, entertainment expenses, and other                 
          business expenses”, sec. 1.162-17(b)(3)(ii), Income Tax Regs.  To           
          account to his employer, within the meaning of section 1.162-               
          17(b)(3), Income Tax Regs., means to submit an expense account or           
          other written statement to the employer showing the business                
          nature and the amount of business expenses.  See sec. 1.162-                
          17(b)(4), Income Tax Regs.                                                  
               Section 274(d) generally provides that no deduction or                 
          credit shall be allowed for travel, entertainment, or a gift                
          unless the taxpayer substantiates such expenditures by adequate             
          records or by sufficient evidence corroborating the taxpayer’s              
          own statement.  See sec. 1.274-5(a), (c), Income Tax Regs.                  
          “Ordinarily, documentary evidence will be considered adequate to            
          support an expenditure if it includes sufficient information to             
          establish the amount, date, place, and the essential character of           
          the expenditure.”  Sec. 1.274-5(c)(2)(iii)(b), Income Tax Regs.             
          Section 274(d) prohibits deductions for expenditures based on               
          approximations or unsupported testimony of the taxpayer.  See               
          sec. 1.274-5(a), Income Tax Regs.                                           
               Deductions are a matter of legislative grace, and the burden           
          of clearly showing the right to the claimed deduction is on                 
          petitioner.  See Rule 142(a); INDOPCO, Inc. v. Commissioner, 503            






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