- 8 - “a high degree of probative value to elevate such statement and evidence” to the level of credibility of a contemporaneous record. Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Thus, no deduction for expenses under section 274(d) may be allowed on the basis of any approximation or the unsupported testimony of the taxpayer. See, e.g., Murata v. Commissioner, T.C. Memo. 1996-321; Golden v. Commissioner, T.C. Memo. 1993-602. In this case, petitioner has attempted to substantiate his expenditures through secondary and incomplete documentation. In particular, petitioner offered credit card statements and a reconstructed summary of his expenditures. Respondent reviewed petitioner’s documents and, after performing a perfunctory analysis, contends that most of the expenditures were for transportation and entertainment. Respondent further contends that the submitted documents do not meet the more stringent requirements of section 274(d). Petitioner, on the other hand, contends that all of the relevant expenditures represented by these documents were incurred in connection with his financial consulting business activity. At trial, petitioner testified that the original documents, which substantiate his claimed job expenses and other miscellaneous deductions, are on his hard drive and in files at Merrill Lynch. However, petitioner has not submitted thosePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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