Evelyn J. Glenn - Page 14




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                Petitioner also deducted on her 1995 and 1996 Schedules C             
           travel expenses in the amounts of $3,271 and $2,667,                       
           respectively.  In the notice of deficiency, respondent                     
           disallowed $2,765 and $2,161 for 1995 and 1996, respectively.              
                At trial, petitioner introduced no documentary evidence               
           regarding travel expense.                                                  
                By virtue of the strict substantiation requirements of                
           section 274(d), no deduction may be allowed either for travel              
           or with respect to any “listed property” on the basis of any               
           approximation or the unsupported testimony of the taxpayer.                
           See Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per            
           curiam 412 F.2d 201 (2d Cir. 1969); Golden v. Commissioner,                
           T.C. Memo. 1993-602; sec. 1.274-5T(a), Temporary Income Tax                
           Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985); see also sec.                    
           280(F)(d)(4)(A)(i) defining listed property to include a                   
           passenger automobile.  Rather, the taxpayer must substantiate              
           the deduction by adequate records, or by sufficient evidence               
           corroborating the taxpayer’s own statement, showing: (1) The               
           amount of each expense or other item; (2) the time and place of            
           the travel or use of the property; and (3) the business purpose            
           of the expense or other item.  See sec. 274(d).  See sec.                  
           1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46014             
           (Nov. 6, 1985), regarding the requisite elements of each                   
           expenditure for travel that must be substantiated; sec. 1.274-             






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