Henry C. Boler and Sherry M. Boler - Page 22




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          travel expenses running errands for AIM.  We disagree that AIM              
          may deduct Mrs. Boler’s travel expenses.  A taxpayer may not                
          deduct travel expenses unless the taxpayer substantiates by                 
          adequate records or sufficient evidence corroborating the                   
          taxpayer's own statement, the amount, time and place, and                   
          business purpose of the expense.  Sec. 274(d)(4).  Petitioners              
          offered no evidence of the amount, time, place, and business                
          purpose of Mrs. Boler’s travel expenses on behalf of AIM.  Thus,            
          petitioners have not complied with section 274(d)(4) as to the              
          claimed deduction in 1994 based on Mrs. Boler’s travel expenses.7           
          H.   Reimbursements Based on Undescribed Journal Entries                    
               Petitioners contend that AIM may deduct the following                  
          expenses coded in AIM’s journals:  $1,254 as GJ1 18308, $600 as             
          GJ1 00172, and $480 as GJ1 001740 (the coded expenses at issue),            
          and reimbursed to petitioner in 1995.  Petitioners contend that             
          Scott incurred, and petitioner paid the coded expenses at issue             
          as, travel expenses relating to a job that Scott did for AIM in             
          Pine Hill, Alabama.  However, petitioners offered no evidence to            
          support that contention.  Petitioners offered no evidence of the            
          time, place, or business purpose of the alleged travel expenses.            





               7  Respondent did not determine and does not contend that              
          the $4,200 amount is a constructive dividend to petitioner.                 





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