William Herbert Whitehurst, III and Carla Cherlene Whitehurst - Page 19




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               b.  Supplies and Repairs and Maintenance Expenses                      
               Petitioners did not produce any documentary evidence or                
          provide any testimony with respect to the deductions for supplies           
          and repairs and maintenance; therefore, we sustain respondent’s             
          disallowance.                                                               
               c.  Travel Expenses (Lodging, Airfare, and Rental                      
               Automobile)                                                            
               Deductible travel expenses include fares, lodging, and                 
          expenses incident to travel.  Sec. 1.162-2(a), Income Tax Regs.             
          No deduction shall be allowed with respect to traveling away from           
          home unless the taxpayer substantiates each element of the                  
          expenditure or use, as described in section 1.274-5T(b),                    
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985), in           
          the manner provided in section 1.274-5T(c), Temporary Income Tax            
          Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).  Sec. 274(d)(1); sec.             
          1.274-5T(a)(1), Temporary Income Tax Regs., supra.  The elements            
          to be substantiated are the amount of each separate expenditure,            
          dates of departure and return and number of days spent away from            
          home on business, destination or locality of travel, and the                
          business reason for travel.  Sec. 1.274-5T(b)(2), Temporary                 
          Income Tax Regs., supra.  Documentary evidence, such as receipts            
          or paid bills, shall be required for any expenditure for lodging            
          while traveling away from home and any expenditure of $75 or                
          more, except with respect to transportation charges, if not                 







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