- 13 - * * * * * * * unless the taxpayer substantiates by adequate records or by sufficient evidence corroborating the taxpayer's own statement (A) the amount of such expense or other item, (B) the time and place of the travel, entertainment, amusement, recreation, or use of the facility or property, * * * (C) the business purpose of the expense or other item, * * * The requirements of section 274(d) are designed to ensure taxpayers maintain records and documentation sufficient to substantiate each expense claimed as a deduction. See Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). Without business records or other proof to substantiate that those expenses were incurred for business purposes, a taxpayer is not entitled to such deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs. Petitioner has presented no evidence concerning any rent payments paid by GTG for 1999. Thus, without any evidence to substantiate the claimed expenses, we find that petitioner is not entitled to any rent expense deduction in excess of the $2,850 allowed by respondent. With respect to the travel and entertainment expenses for both 1999 and 2000, petitioner’s evidence consisted of financial records in the form of copied receipts, bills, credit card statements, and a single expense report from a GTG employee. Petitioner did not offer any testimony as to the business purpose of any of the expenses noted in the financial records. For example, while the expense report vaguely listed several costs,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011