- 22 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011