Jon A. and Linda A. Jewett - Page 4

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          regulations which except taxpayers from strict substantiations in           
          the case of expenditures of less than a prescribed amount.                  
          Petitioner, like the taxpayer in Johnson, has not shown that he             
          made any expenditure that fits within these exceptions.  Johnson            
          v. Commissioner, supra at 228 n.11.                                         
               Section 274(d) imposes stringent substantiation requirements           
          for the deduction of travel expenses.  Taxpayers must                       
          substantiate by adequate means certain elements in order to claim           
          deductions, such as the amount of such expenditure, the date of             
          the expenditure or use, the place of each separate expenditure,             
          and the business purpose for an expenditure or use.  Sec. 274(d);           
          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, a taxpayer must maintain an account book, diary, log,              
          statement of expense, trip sheets, and/or other documentary                 
          evidence, which, in combination, are sufficient to establish each           
          element of expenditure or use.  The log must be made at or near             
          the time of the expenditure.  Sec. 1.274-5T(c)(2)(i) and (ii),              
          Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).              
               Petitioner claimed that he prepared a log listing his travel           
          expenses at or near the times of the expenditures.  We are not              
          required to accept petitioner’s self-serving statements.                    
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).  Our review of             
          this log leads us to conclude it was prepared at one time, and              






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