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made at or near the time of the expenditure or use,
supported by sufficient documentary evidence, has a
high degree of credibility not present with respect to
a statement prepared subsequent thereto when generally
there is a lack of accurate recall. Thus, the corrobo-
rative evidence required to support a statement not
made at or near the time of the expenditure or use must
have a high degree of probative value to elevate such
statement and evidence to the level of credibility
reflected by a record made at or near the time of the
expenditure or use supported by sufficient documentary
evidence. The substantiation requirements of section
274(d) are designed to encourage taxpayers to maintain
the records, together with documentary evidence, as
provided in paragraph (c)(2) of this section [1.274-5T,
Temporary Income Tax Regs.].
Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
46016-46017 (Nov. 6, 1985).
The elements that a taxpayer must prove with respect to an
expenditure for traveling away from home on business, including a
meal, are: (1) The amount of each such expenditure for traveling
away from home, except that the daily cost of the traveler’s own
breakfast, lunch, and dinner may be aggregated; (2) the time of
each such expenditure, i.e., the dates of departure and return
for each trip away from home and the number of days away from
home spent on business; (3) the place of each such expenditure,
i.e., the destinations or locality of travel, described by name
of city or town or other similar designation; and (4) the busi-
ness purpose of each such expenditure, i.e., the business reason
for the travel or the nature of the business benefit derived or
expected to be derived as a result of travel. Sec. 1.274-
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