- 4 - 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, andPage: Previous 1 2 3 4 5 6 Next
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