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The heightened substantiation requirements of section 274
apply to deductions for travel expenditures. Sec. 274(d)(1).
Under section 274(d)(1), the elements that must be substantiated
to deduct such expenses generally include the amount of each
separate expenditure, the dates of departure and return for each
trip away from home and the number of days away from home spent
on business, the destinations or places to which the taxpayer
traveled, and the business purpose of the travel. Sec. 1.274-
5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6,
1985). As with other deductions to which section 274 applies,
taxpayers must generally substantiate deductions for business
travel away from home with “adequate records” or “sufficient
evidence corroborating the taxpayer’s own statement”, discussed
supra. Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., supra.
Petitioners attempted to substantiate a portion of the
claimed business travel deductions in 1999. Petitioners
presented a Quicken report containing Dr. Rinker’s travel
expenditures in 1999, and Dr. Rinker testified that some of the
travel expenditures on the report related to business trips that
she took to attend various medical conferences. In her
testimony, Dr. Rinker specified which trips on the report were
business travel and detailed the business activities she engaged
in during those trips.
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