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See sec. 1.274-5T, Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985). As applicable here, “listed property” includes
expenses associated with computer equipment and cellular
telephones. Sec. 280F(d)(4).
To substantiate a deduction under section 274(d), a taxpayer
must maintain adequate records or present other corroborative
evidence to show, inter alia, the amount of the expense, the date
upon which it was incurred, and the business purpose for the
expenditure. Sec. 1.274-5T(b), Temporary Income Tax Regs., 50
Fed. Reg. 46014 (Nov. 6, 1985). To substantiate a deduction by
means of adequate records, the taxpayer must present some type of
documentary evidence. Sec. 1.274-5T(c)(2)(i), Temporary Income
Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
The parties stipulated that reimbursements received from
CPSG, Inc. were “primarily” for travel and entertainment,
supplies, and telephone expenses. Respondent allowed as a
deduction the full amount of the expenses associated with the
reimbursements. Additionally, respondent allowed petitioners to
deduct their automobile expenses as an itemized deduction.
The substantiation requirements of sections 6001 and 274(d)
require, at a minimum, that petitioners substantiate the expenses
deducted. Some of the items for which deductions were claimed
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