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Under section 274(d), all travel expense deductions must meet
stringent substantiation requirements. Petitioner did not
satisfy the substantiation requirements of section 274(d).
Under section 274(d), no deduction is allowed under section
162 for any travel expense:
unless the taxpayer substantiates by adequate records
or by sufficient evidence corroborating the taxpayer’s
own statement (A) the amount of such expense or other
item, (B) the time and place of the travel,
entertainment, amusement, recreation, or use of the
facility or property, or the date and description of
the gift, (C) the business purpose of the expense of
other item. * * *
To substantiate a deduction by adequate records, a taxpayer must
maintain an account book, diary, log, statement of expense, trip
sheets, and/or other documentary evidence, which, in combination,
are sufficient to establish each element of expenditure or use.
Sec. 1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg.
46017 (Nov. 6, 1985).
Petitioner did not produce any records for travel taken
during 1992 and 1993. He did not maintain a log for mileage
deductions claimed, nor did he offer any statement of expense or
receipts for his trips between California and Idaho. Petitioner
offered only his uncorroborated testimony as evidence of the
claimed travel expenses. Section 274(d) expressly requires
corroboration of any statement by the taxpayer as to amounts
expended for travel. Petitioner has failed to meet the strict
substantiation requirements of section 274(d).
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