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Here, although Mr. Strong testified to some of the travel
expenses and provided copies of some canceled checks, SCC did not
provide adequate substantiation to meet the strict requirements
of section 274(d). The record does not include any receipts,
vouchers, itineraries, diaries, logs, or calendars made in
connection with the alleged travel expenses, nor any other
evidence sufficient to corroborate Mr. Strong’s testimony.
Accordingly, we sustain respondent’s determinations with respect
to these travel expenses for the years 1991 through 1994.
5. Miscellaneous Expenses
a. Office Supplies and General Supplies Expenses
SCC contests respondent’s disallowance of the deductions
claimed for office supplies and general supplies incurred for
1991, 1992, 1993, and 1994 of $797.96, $611.16, $396.12, and
$1,102.14, respectively. Of these amounts, respondent allowed
$326 for 1991, $495.52 for 1992, $386.66 for 1993, and $518.01
for 1994.
However, SCC contends that it is entitled to additional
office and general supplies expenses that were not allowed by
respondent. SCC offered as proof only copies of canceled checks.
The canceled checks do not show in any detail the items purchased
or the business purpose for the items, as required to
substantiate the claimed deductions. See sec. 1.162-17, Income
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