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expenses is required. Sec. 274(d); sec. 1.274-5T(a)(l),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
To meet the adequate records requirements of section 274(d), a
taxpayer "shall maintain an account book, diary, log, statement
of expense, trip sheets, or similar record * * * and documentary
evidence * * * which, in combination, are sufficient to establish
each element of an expenditure". Sec. 1.274-5T(c)(2)(i),
Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
The elements to be proven with respect to each traveling expense
are the amount, time, place, and business purpose of the travel.
Sec. 1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg.
46014 (Nov. 6, 1985). These substantiation requirements are
designed to encourage taxpayers to maintain records, together
with documentary evidence substantiating each element of the
expense sought to be deducted. Sec. l.274-5T(c)(l), Temporary
Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
Petitioner offered little or no evidence at trial with
respect to his parking, car and truck, travel, meals, and
entertainment expenses that would satisfy the requirements of
section 274(d) and the regulations cited. Similarly, no evidence
of petitioner’s membership expenses was submitted. While
petitioner claimed to have offered more evidence to respondent’s
agent during the audit, that evidence was conspicuously lacking
at trial, particularly considering petitioner’s profession as a
litigator. To the extent petitioner used his vehicle to commute
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