Katumba P. Kashama - Page 6

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          records or by other sufficient evidence corroborating the claimed           
          expenses is required.  Sec. 274(d); sec. 1.274-5T(a)(1),                    
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              
          To meet the adequate records requirements of section 274(d), a              
          taxpayer “shall maintain an account book, diary, log, statement             
          of expense, trip sheets, or similar record * * * and documentary            
          evidence * * * which, in combination, are sufficient to establish           
          each element of an expenditure”.  Sec. 1.274-5T(c)(2)(i),                   
          Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).              
          These substantiation requirements are designed to encourage                 
          taxpayers to maintain records, together with documentary evidence           
          substantiating each element of the expense sought to be deducted.           
          Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg.               
          46016 (Nov. 6, 1985).                                                       
               Petitioner’s records with respect to his car and truck                 
          expenses do not satisfy the requirements of section 274(d) and              
          the regulations cited.  Petitioner claimed that he kept adequate            
          books and records but that they were stolen from his car.                   
          Petitioner also claimed that Pillow Express maintained records of           
          his mileage, but he provided no substantiation from the company.            
               When asked about the seemingly inflated amount of car and              
          truck expenses claimed on his 2001 Federal income tax return,               
          petitioner stated:  “I was just going to guess in my head, at the           
          time I was doing the taxes.  * * *  I was just guessing because,            






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