Gunasundran R. Pillay and Kalaivani Govender - Page 9

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          however, at the very least his testimony casts doubt on his                 
          assertion that WTS was a separate business.5                                
               Even if WTS was a separate business, each of the claimed               
          expense deductions fails to satisfy one or more requirements to             
          be deductible.  With respect to travel, meals, and entertainment            
          expenses, petitioner has not met the substantiation requirements            
          of section 274(d).  Although petitioner introduced a number of              
          receipts, they do not describe the business purpose of the                  
          expenses or the business relationship to petitioner of the                  
          persons he entertained.  See sec. 274(d); sec. 1.274-5T(b),                 
          Temporary Income Tax Regs., supra.                                          
               Petitioner testified that he purchased a vehicle that he               
          used exclusively for WTS-related business, even though title to             
          the vehicle was held in petitioners’ names rather than in WTS’s             
          name.   Because the vehicle was listed property as defined in               
          section 280F(d)(4)(A), deductions related to the vehicle are also           
          subject to the heightened substantiation requirements of section            
          274(d).  Petitioner did not keep a mileage log, however, or                 
          otherwise corroborate his testimony concerning the business                 
          purpose of the vehicle.  See sec. 274(d); sec. 1.274-5T(c),                 
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              


               5 Petitioner’s belief that WTS was related to his employment           
          with SBOE may explain why he originally claimed the $12,488 of              
          additional Schedule C deductions as unreimbursed employee                   
          expenses.  See supra note 3.                                                





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