Neal N. and Ruby W. Viar - Page 11

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          passenger automobiles, cell phones, and other similar                       
          telecommunications equipment under section 280F(d)(4)(A), section           
          274(d) imposes stringent substantiation requirements to document            
          particularly the nature and amount of such expenses.  For such              
          expenses, substantiation of the amounts claimed by adequate                 
          records or by other sufficient evidence corroborating the claimed           
          expenses is required.  Sec. 274(d); sec. 1.274-5T(a)(1),                    
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              
          To meet the adequate records requirements of section 274(d), a              
          taxpayer "shall maintain an account book, diary, log, statement             
          of expense, trip sheets, or similar record * * * and documentary            
          evidence * * * which, in combination, are sufficient to establish           
          each element of an expenditure".  Sec. 1.274-5T(c)(2)(i),                   
          Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).              
          The elements to be proven with respect to each traveling expense            
          are the amount, time, place, and business purpose of the travel.            
          Sec. 1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg.               
          46014 (Nov. 6, 1985).  These substantiation requirements 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)(l), Temporary              
          Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).                        
               Petitioners’ records with respect to the car and truck                 
          expenses and travel, meals, and entertainment expenses do not               

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