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beyond the taxpayer’s control. Sec. 1.274-2(c)(3), Income Tax
Regs.
A taxpayer must satisfy the same substantiation requirements
of section 274(d) for listed property as defined under section
280F(d)(4). Listed property includes any cellular telephone (or
similar telecommunications equipment). Sec. 280F(d)(4)(A)(v).
Under section 274(b) deductions for gifts made by the
taxpayer to an individual are not allowed to the extent that such
expense, when added to prior expenses of the taxpayer for gifts
made to such individual during the taxable year, exceeds $25.
Sec. 1.274-3(a), Income Tax Regs. The business gift must also be
ordinary and necessary under section 162.
Because petitioner provided supporting canceled checks,
invoices and bills, and other substantiating information, we are
satisfied that petitioner has provided credible evidence and
satisfied the requirements of section 162 and (if applicable)
section 274(a)(1), (2)(A), and (d) concerning the time, place of
use, business purpose of, and business relationship to clients,
with respect to the following claimed expenses:
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