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This section “contemplates that no deduction or credit shall be
allowed a taxpayer on the basis of such approximations or
unsupported testimony of the taxpayer.” Sec. 1.274-5T(a),
Temporary Income Tax Regs., supra.
In order to substantiate a deduction by means of adequate
records, a taxpayer must maintain a diary, log, statement of
expenses, trip sheet, or similar record, and documentary evidence
which, in combination, are sufficient to establish each element
of each expense or use. Sec. 1.274-5T(c)(2)(i), Temporary Income
Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). A contemporaneous
log is not required, but corroborative evidence to support a
taxpayer’s record of the elements of expenditure or use must have
“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., supra.
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.
Petitioner testified that the job expenses incurred during
taxable year 1999 were for expenses incurred in furtherance of
his occupation as a high school English teacher employed by the
Chicago Department of Education. Petitioner also testified that
the expenses were incurred in attending English literature
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