- 19 - therefore unsubstantiated and disallowed.16 See secs. 162(a), 212(1); Hradesky v. Commissioner, supra at 89-90. As for the meal, travel, and vehicle expenses that require strict substantiation, respondent contends that petitioner failed to substantiate strictly $1,091 in travel expenses and $113 in meal expenses. Respondent argues that while petitioner documented his payment of some of the amounts charged, he substantiated neither the “business purpose” of the expenses nor the “business relationship” to him of any persons entertained. We agree that petitioner has not strictly substantiated these expenses. Petitioner frequently traveled on business and incurred meal and travel expenses, which his employer did not reimburse.17 Yet petitioner substantiated only the time and amount of certain of these expenses, and of those amounts he did not adequately establish the business relationship between the expenses and his business for Selane Products. See sec. 274(d) (flush language). Petitioner substantiated certain expenses with credit card receipts and a personal calendar. While some of those expenses coincided with business functions, petitioner did not explain the 16Petitioner gave us no basis to apply the Cohan rule to estimate his expenses. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). 17Petitioner incurred the vehicle expenses for travel between two Selane Products buildings.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011