- 56 - taxpayer to substantiate by adequate records or by sufficient evidence to corroborate the taxpayer’s own testimony: (a) The amount of the expenditure, (b) the time and place of the expenditure, (c) the business purpose of the expenditure, and (d) the business relationship to the taxpayer of the person being entertained. For 1989, petitioner claims a business expense deduction of $180 for the cost of meals billed through the Vassar Club. Inconsistencies between the handwritten and printed receipts from the Vassar Club, however, prevent us from finding that she has adequately substantiated the business meal deductions claimed. Nor has she adequately demonstrated the business purposes of claimed travel expenses totaling $343 for separate trips in 1989 to Florida and to Washington, D.C. Petitioner also claims deductions in 1989 for $3,000 in legal and professional fees paid to the law firm of Saltzman & Holloran and to the Prentice-Hall Financial Service relating to the incorporation of Real Services. She also seeks to deduct the filing fees charged for such incorporation. Assuming arguendo that the claimed expenses of incorporating a corporation found to be a sham for tax purposes have a business purpose, these expenses would nevertheless not be deductible in 1989;19 these 19 Organizational expenses incurred and paid by a corporation can be amortized at its election over a 60-month (continued...)Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
Last modified: May 25, 2011