Daniel R. Allemeier, Jr. - Page 18

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          amount, time and place, and business purpose of the expense, as             
          well as the business relationship to the taxpayer of the persons            
          involved in the claimed expenses.  Id. (flush language).                    
          Adequate records require the taxpayer to maintain a diary, a log,           
          or a similar record, and documentary evidence that, in                      
          combination, are sufficient to establish each element of each               
          expenditure or use.  Sec. 1.274-5T(c)(2)(i), Temporary Income Tax           
          Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).  A record must                    
          generally be written contemporaneously with the expenditure.                
          Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income Tax Regs., supra.              
          Against this background, we now analyze whether petitioner                  
          satisfied substantiation requirements for his claimed deductions.           
               Overall, petitioner claimed $17,500 in business expenses of            
          which he conceded $833.  Of the remaining $16,667, $15,745 was              
          attributable to the tuition expenses that petitioner                        
          substantiated, for which we granted a deduction.  The remaining             
          amounts are $922 in miscellaneous business expenses, $40 in tax             
          preparation fees, $104 in vehicle expenses, $1,091 in travel                
          expenses, and $113 in meal expenses.                                        
               Petitioner contends that he lost records supporting expense            
          deductions for the tax preparation fees and miscellaneous                   
          business expenses.  He has failed to reconstruct adequately those           
          records or otherwise corroborate those items.  These expenses are           







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