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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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