Samie M. and Nora L. Finch - Page 10

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                         (1) under section 162 or 212 for any traveling               
                    expense (including meals and lodging while away                   
                    from home),                                                       
                         (2) for any item with respect to an activity which           
                    is of a type generally considered to constitute                   
                    entertainment, amusement, or recreation, or with                  
                    respect to a facility used in connection with such                
                    an activity,                                                      
                         (3) for any expense for gifts, or                            
                         (4) with respect to any listed property (as                  
                    defined in section 280F(d)(4)),                                   
               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, or the date            
               and description of the gift, (C) the business purpose of the           
               expense or other item, and (D) the business relationship to            
               the taxpayer of persons entertained, using the facility or             
               property, or receiving the gift.  * * *                                
          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           





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