- 7 - v. Flowers, supra at 470. If a taxpayer’s otherwise deductible traveling expenses are reimbursed by his employer, the taxpayer is entitled to a deduction only for amounts in excess of the reimbursements, and only if properly substantiated. See sec. 1.162-17(b)(3), Income Tax Regs.; sec. 1.274-5T(f)(2)(iii), (5)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46028 (Nov. 6, 1985). Section 274(d) imposes stringent substantiation requirements for deductions related to travel, entertainment, gifts, and “listed property (as defined in section 280F(d)(4))”. Otherwise allowable deductions for these types of expenses are not allowed 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 or other item, and (D) the business relationship to the taxpayer of persons entertained, using the facility or property, or receiving the gift. * * * Sec. 274(d). To substantiate his traveling expenses, petitioner produced a travel log and numerous credit card receipts. According to petitioner, expenses incurred in connection with his employment with the DOI are recorded in the travel log. On a day-by-day basis, petitioner’s travel log lists expenses for breakfast, lunch, dinner, business meals, entertainment, tips (generally forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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