Kevin J. and Crystal A. Shoemaker - Page 10

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         business use based on the appropriate measure, e.g., mileage for             
         automobiles and time for cellular phones, of such property;                  
         (2) the time, i.e., the date of the expenditure or use with                  
         respect to any such property; and (3) the business purpose for an            
         expenditure or use with respect to such property.  Sec. 1.274-               
         5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,            
         1985).                                                                       
              The elements that a taxpayer must prove with respect to an              
         expenditure for traveling away from home on business, including              
         meals, are:  (1) The amount of each such expenditure for travel-             
         ing 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-                   
         5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46014-46015               
         (Nov. 6, 1985).                                                              
              In lieu of substantiating the actual amount of any expendi-             
         ture relating to the business use of a passenger automobile, a               






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