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1. Travel
Respondent disallowed $1,308 of petitioner’s 1991 travel
expense deduction for failure to substantiate the amounts by the
necessary records.
The amount of business travel must be substantiated “by the
use of a contemporaneous log of business travel, or by any
reasonable means establishing the number of miles traveled, the
date, the place, and the business purpose of such miles”.
Kravette v. Commissioner, T.C. Memo. 1987-124 (citing Smith v.
Commissioner, 80 T.C. 1165, 1171-1173 (1983)); see also sec.
1.274-5T(a)(1), Temporary Income Tax Regs., supra.
Petitioner testified that she traveled to Brookfield,
Wisconsin, for a seminar but failed to provide the location and
title of the seminar and an explanation of how the seminar was
related to her business. Petitioner also traveled to Boston with
her fianc� to visit a cousin who was purportedly interested in
opening a franchise of Dustbusters. Finally, petitioner provided
a Budgetel Inn invoice for an overnight stay without a disclosed
location and purpose. Besides being unable to substantiate the
amount claimed on petitioner’s Schedule C by the receipts
provided, petitioner failed to submit any evidence of a
contemporaneous notation showing how the expenses were reasonable
and necessary in the pursuit of her business. At trial,
petitioner testified to the business purpose of the travel
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