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Under section 1.170A-13(a)(1), Income Tax Regs., a taxpayer
is required to maintain for each charitable contribution a
canceled check, a receipt from the donee organization, or other
reliable written records of the contribution. Because Mr. Strong
presented copies of canceled checks for the $73.14 in 1991 and
$80 in 1993, we conclude that SCC is allowed these charitable
contributions. However, because Mr. Strong failed to
substantiate the $220 contribution, we conclude that SCC is
precluded from deducting the $220 for the year 1992 as a
charitable contribution.
4. Travel Expenses
SCC claimed travel expenses for the years 1991-94 of
$1,914.59, $397.79, $148.62, and $1,045.67, respectively.
Respondent disallowed these travel expenses.
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). Accordingly, 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., Sanford v. Commissioner, 50 T.C. 823, 827-
828 (1968), affd. 412 F.2d 201 (2d Cir. 1969).
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