Gunasundran R. Pillay and Kalaivani Govender - Page 7

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          Loan Association, 403 U.S. 345, 352 (1971); FMR Corp. & Subs. v.            
          Commissioner, 110 T.C. 402, 414 (1998).                                     
               Section 274(d) imposes strict substantiation requirements              
          for listed property as defined in section 280F(d)(4), gifts,                
          travel, entertainment, and meal expenses.  Sec. 1.274-5T(a),                
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              
          Listed property includes passenger automobiles and any other                
          property used as a means of transportation.  Sec.                           
          280F(d)(4)(A)(i) and (ii).  To obtain a deduction for a listed              
          property, travel, meal, or entertainment expense, a taxpayer must           
          substantiate by adequate records or sufficient evidence to                  
          corroborate the taxpayer’s own testimony the amount of the                  
          expense, the time and place of the use, the business purpose of             
          the use, and, in the case of entertainment, the business                    
          relationship to the taxpayer of each person entertained.  Sec.              
          274(d); sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed.               
          Reg. 46014 (Nov. 6, 1985).                                                  
                According to respondent, petitioners have not demonstrated            
          that WTS was a separate business activity in the years at issue.            
          Respondent therefore contends that none of petitioners’ claimed             
          deductions were paid or incurred in carrying on a trade or                  
          business.  Respondent notes that WTS and the corporation had                
          similar names and shared office space, that WTS had only one                
          client, and that WTS had no gross income, whereas the corporation           






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