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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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