- 33 - 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).Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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