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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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