- 32 - With respect to petitioner’s $31,860 casualty loss that he claimed for 1991, he testified that this was Mrs. Corrigan’s loss and that there was an insurance recovery. Accordingly, petitioner is not entitled to any part of the $31,860 casualty loss that he claimed for 1991. C. Employee Expenses Petitioner claimed deductions for each year at issue in connection with his employment. The deductions concerned travel, meals, and other employee-type expenses. A taxpayer may deduct ordinary and necessary business expenses incurred in conducting a trade or business. Sec. 162(a). The term “trade or business” includes the trade or business of being an employee. Primuth v. Commissioner, 54 T.C. 374, 377 (1970). Section 274, however, limits deductions for entertainment and recreation that would otherwise be allowable unless it is established that the expenditures were directly related to or preceding a bona fide business discussion and were associated with the active conduct of a taxpayer’s trade or business. See sec. 274(a)(1)(A). A deduction is allowed for meals only if such expenses are not lavish and the taxpayer is present when such meals are furnished. Sec. 274(k)(1). In addition, section 274(d) limits such deductions to those that can be substantiated by adequate records or other evidence corroborating the amount of the expenditure, the time and placePage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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