Inez T. Morin - Page 6




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          statement of expense, trip sheet, and/or other documentary                  
          evidence, which, in combination, are sufficient to establish each           
          element of expenditure or use.  Sec. 1.274-5T(c)(2)(i), Temporary           
          Income Tax Regs., 50 Fed Reg. 46017 (Nov. 6 1985).  Travel,                 
          automobile, and entertainment expenses cannot be estimated under            
          Cohan.  Sanford v. Commissioner, 50 T.C. 823, 827-828 (1968),               
          affd. per curiam 412 F.2d 201 (2d Cir. 1969).                               
               Petitioner did not have any books or records.  She did not             
          have a diary, a log, or trip sheets relating to her travel.  At             
          trial, petitioner had little evidence to support many of her                
          claimed deductions.  Many expenses appeared to be personal                  
          expenses nondeductible under section 262.  Petitioner provided              
          some substantiation for business expense deductions and                     
          respondent conceded that she was entitled to most of those                  
          deductions.                                                                 
               Petitioner was asked whether she could provide for MBS:                
          “Any kind of books or records that might show that [she] had any            
          reason to travel that year”.  Petitioner’s answer was:  “Not with           
          me, no.”  Petitioner failed to comply with the strict                       
          substantiation rules of section 274(a) and is not entitled to               
          deduct any travel, meals, and entertainment expenses.  As to the            
          claimed $2,378 bad debt deduction for MBS, petitioner said:  “I             
          mean, it’s not worth the headache to point out all the returned             
          checks, and matching it [sic] to my deposits” so she conceded               





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