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the trip to Jamaica that petitioner claims to have taken place in
January 1998. As with the deduction for meals and expenses, this
deduction is also subject to section 274(d). In support of the
deduction for these expenses, petitioner produced a canceled
check and a travel summary from his travel agent, Vacation
Hotline.
We need not consider whether these records in combination
with petitioner’s explanation satisfy the special substantiation
requirements discussed above because another, more fundamental
reason exists for the disallowance of the deduction. Although
petitioner claims that the trip occurred during 1998, we find
that the trip took place in January 1999. We support our finding
on this point by the following: (1) Although the check is dated
January 16, 1998, imprints on the back of the check indicate that
the check was processed by two banks on January 20, 1999, and
January 21, 1999, respectively; (2) it is not unusual for an
individual to misdate a check at the beginning of a new year, and
we find it more likely that petitioner made such a mistake rather
than the two different banks that processed the check; (3)
Vacation Hotline’s records indicate that petitioner was in
Tallahassee, Florida, rather than Jamaica, during the relevant
dates in January 1998; and (4) the number of the check suggests
that it was made at a date no earlier than December 10, 1998.
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