- 13 - 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-Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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