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section 274(d), the substantiation requirement is fulfilled if
the employee provides information sufficient to satisfy the
substantiation requirements of section 274(d) and the regulations
thereunder to the employer. Sec. 1.62-2(e)(2), Income Tax Regs.
Section 274(d) allows a deduction for expenses of traveling away
from home only if an employee substantiates the amount, date,
time, place, and business purpose for the travel. Sec. 1.274-
5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6,
1985). For business expenses not governed by section 274(d), the
employee must submit information to the employer sufficient to
enable the employer to identify the specific nature of each
expense and conclude that the expense is attributable to the
employer’s business activities. For these nonsection 274(d)
expenses, each of the elements of an expenditure or use must be
substantiated to the payor. Sec. 1.62-2(e)(3), Income Tax Regs.
Petitioner and Mr. Kerkinni testified that petitioner
submitted a list of expenses and receipts to Mr. Kerkinni
annually. In addition, before making expenditures on behalf of
IMC, petitioner would inform Mr. Kerkinni that his work required
a certain piece of equipment, and, with Mr. Kerkinni’s
permission, he would purchase what was needed. Petitioner would
then show Mr. Kerkinni the receipts. Mr. Kerkinni asked
petitioner to keep track of and save the receipts. Petitioner’s
lists and receipts were submitted at trial. The lists provided
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