Timothy Dean Strong - Page 33

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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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