Elliot S. and Darlene M. Saffran - Page 5

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          or use, and the business purpose for an expenditure or use.  Sec.           
          274(d); sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed.            
          Reg. 46016 (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 sheet or similar record,             
          and/or other documentary evidence, which, in combination, are               
          sufficient to establish each element of expenditure or use.  Sec.           
          1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017           
          (Nov. 6, 1985).  Each recording of an element of an expenditure             
          or use must be made at or near the time of the expenditure or               
          use.  Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income Tax Regs., 50            
          Fed. Reg. 46017 (Nov. 6, 1985).  A taxpayer who is unable to                
          satisfy the adequate records requirement is still entitled to a             
          deduction for expenses that he can substantiate with other                  
          corroborative evidence.  Sec. 1.274-5T(c)(3), Temporary Income              
          Tax Regs., 50 Fed. Reg. 46020 (Nov. 6, 1985).  When section                 
          274(d) applies, as here, this Court cannot rely on Cohan v.                 
          Commissioner, 39 F.2d 540 (2d Cir. 1930), to estimate the                   
          taxpayer’s expenses.  Sanford v. Commissioner, 50 T.C. 823, 827-            
          828 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969).                   
               Respondent disallowed $3,243 of petitioner’s claimed $6,905            
          deduction for car and truck expenses.  Petitioner submitted a so-           
          called log listing his travel expenses.  We are not required to             
          accept petitioner’s self-serving statements as gospel.  Tokarski            






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