- 18 - 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 arePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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