Karan M. Hintze - Page 11

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          satisfy the strict substantiation requirements of section 274(d)            
          in order for a deduction to be allowed.  The expenses to which              
          section 274(d) applies include, among other things, traveling               
          expenses (which include expenses for meals and lodging while away           
          from home), and entertainment expenses.  See sec. 274(d)(1) and             
          (2).  We may not use the Cohan doctrine to estimate expenses                
          covered by section 274(d).  See Sanford v. Commissioner, 50 T.C.            
          823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969);              
          sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014            
          (Nov. 6, 1985).                                                             
               1.   Traveling Expenses                                                
               On her return, petitioner claimed a deduction for traveling            
          expenses of $8,531 for tax year 1994.  Of this amount, respondent           
          concedes a deduction of $347 for expenses incurred by petitioner            
          for parking.  At trial, petitioner introduced copies of receipts            
          and other documentation in support of her contention that she               
          incurred traveling expenses of $9,003.69.                                   
               Traveling expenses are subject to the substantiation                   
          requirements of section 274(d).  See sec. 274(d)(1).  No                    
          deduction is allowed for expenses incurred for travel away from             
          the taxpayer’s home (including meals and lodging) unless the                
          taxpayer substantiates, by adequate records or by sufficient                
          evidence corroborating the taxpayer’s own statement, each of the            
          following elements:  (1) The amount of each separate expenditure;           

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