- 5 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011