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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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