Marcelo E. Ferrada and Gloria D. Ferrada - Page 9

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          claimed pursuant to sections 162 and 212 are ordinary and                   
          necessary expenses and must maintain records sufficient to                  
          substantiate the amounts of the deductions claimed.  Sec. 6001;             
          Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965); sec.                
          1.6001-1(a), (e), Income Tax Regs.                                          
               With respect to certain business expenses specified in                 
          section 274(d), however, more stringent substantiation                      
          requirements apply.  Section 274(d) disallows deductions for                
          traveling expenses, gifts, and meals and entertainment, as well             
          as for listed property, unless the taxpayer substantiates by                
          adequate records or by sufficient evidence corroborating the                
          taxpayer's own statement:  (1) The amount of the expenses,                  
          (2) the time and place of the expense, (3) the business purpose             
          of the expense, and (4) the business relationship to the taxpayer           
          of the persons involved in the expense.  The term "listed                   
          property" is defined in section 280(F)(d) and includes passenger            
          vehicles and computers.  See sec. 280F(d)(4)(i).                            
               The substantiation requirements of section 274(d) are                  
          designed to encourage taxpayers to maintain records, together               
          with documentary evidence substantiating each element of the                
          expense sought to be deducted.  Sec. 1.274-5T(c)(1), Temporary              
          Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).                        
               Under section 274(d), substantiation by means of adequate              
          records requires a taxpayer to maintain a diary, a log, or a                






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