- 5 - 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 concededPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011