- 28 - 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, 503Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011