Michael Gregorian and Yolanda Gregorian a.k.a. Yolanda Trelles - Page 9

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               Section 162 allows a deduction for ordinary and necessary              
          expenses that are paid or incurred during the taxable year in               
          carrying on a trade or business.  Sec. 162(a); Deputy v. duPont,            
          308 U.S. 488, 495 (1940).  In the case of travel expenses and               
          certain other expenses, such as entertainment, gifts, and                   
          expenses relating to the use of listed properties, including                
          passenger vehicles and other property used as a means of                    
          transportation, computers, and cellular phones under section                
          280F(d)(4)(A), section 274(d) imposes stringent substantiation              
          requirements to document particularly the nature and amount of              
          such expenses.  For such expenses, substantiation of the amounts            
          claimed by adequate records or by other sufficient evidence                 
          corroborating the claimed expenses is required.  Sec. 274(d);               
          sec. 1.274-5T(a)(1), Temporary Income Tax Regs., 50 Fed. Reg.               
          46014 (Nov. 6, 1985).  To meet the adequate records requirements            
          of section 274(d), a taxpayer “shall maintain an account book,              
          diary, log, statement of expense, trip sheets, or similar record            
          * * * and documentary evidence * * * which, in combination, are             
          sufficient to establish each element of an expenditure”.  Sec.              
          1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017           
          (Nov. 6, 1985).  These substantiation requirements are designed             
          to encourage taxpayers to maintain records, together with                   
          documentary evidence substantiating each element of the expense             







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