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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 for
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