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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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