Daniel R. Allemeier, Jr. - Page 19

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          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.                                      




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