Carl F. and Frances R. Butler - Page 14

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          This section “contemplates that no deduction or credit shall be             
          allowed a taxpayer on the basis of such approximations or                   
          unsupported testimony of the taxpayer.”  Sec. 1.274-5T(a),                  
          Temporary Income Tax Regs., supra.                                          
               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).  A contemporaneous            
          log is not required, but corroborative evidence to support a                
          taxpayer’s record of the elements of expenditure or use must have           
          “a high degree of probative value to elevate such statement and             
          evidence” to the level of credibility of a contemporaneous                  
          record.  Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., supra.            
          Thus, 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., Murata v. Commissioner,              
          T.C. Memo. 1996-321; Golden v. Commissioner, T.C. Memo. 1993-602.           
               At trial, Mrs. Butler testified that she calculated the                
          Schedule C expenses herself and gave her accountant the                     
          worksheets with these calculations to complete petitioners’ tax             
          return.  However, Mrs. Butler did not offer her detailed                    
          worksheets into evidence.  She did not keep a trip sheet or log             






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