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In this case, specific substantiation rules come into play
as the deductions here in dispute, although of a type generally
allowable under section 162(a), are further described in and
subject to section 274(d). In general, that section provides
that no deduction shall be allowed for any travel expense or
entertainment expense unless the taxpayer substantiates by
adequate records the following items: (1) The amount of such
expense; (2) the time and place of the travel or entertainment;
(3) the business purpose of the expense; and (4) the business
relationship to the taxpayer of persons entertained. Sec.
274(d); sec. 1.274-5T(b)(2) and (3), Temporary Income Tax Regs.,
50 Fed. Reg. 46014-46015 (Nov. 6, 1985).
Under the applicable regulations, to meet the “adequate
records” requirement 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). The record-
keeping requirements of section 274(d) contemplate that a record
“made at or near the time of the expenditure or use, supported by
sufficient documentary evidence, has a high degree of credibility
not present with respect to a statement prepared subsequent
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