W. Bradford Davis and Tedde M. Rinker - Page 30

                                       - 30 -                                         
          (Nov. 6, 1985), provides a way to maintain the confidentiality of           
          information when recording the elements of business mileage in a            
          log book or similar document:                                               
                    Confidential information.--If any information                     
                    relating to the elements of an expenditure or                     
                    use, such as place, business purpose, or                          
                    business relationship, is of a confidential                       
                    nature, such information need not be set                          
                    forth in the account book, diary, log,                            
                    statement of expense, trip sheet, or similar                      
                    record, provided such information is recorded                     
                    at or near the time of the expenditure or use                     
                    and is elsewhere available to the district                        
                    director to substantiate such element of the                      
                    expenditure or use.                                               
          As respondent noted--albeit in another context--petitioners could           
          have satisfied this requirement by photocopying Dr. Rinker’s                
          appointment book and redacting her clients’ names.  Petitioners             
          failed to do so.                                                            
               Petitioners have not presented any evidence to corroborate             
          Dr. Rinker’s statements regarding her business mileage.  They               
          have therefore failed to substantiate any such expenses.  We                
          allow no deduction for business mileage.                                    
          b.  Business Travel Away From Home                                          
               Petitioners deducted $7,018 for business travel away from              
          home and $988 for business meals and entertainment.  Respondent             
          disallowed all but $362 of the claimed deductions for travel.               
          Respondent made no adjustment to petitioners’ deduction for meals           
          and entertainment of $988.                                                  







Page:  Previous  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  Next

Last modified: May 25, 2011