Charles E. Townsend - Page 11

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               log is not required, but a record of the elements of an                
               expenditure or of a business use of listed property                    
               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              
         expenditures for the use of his automobile, lodging, meals, and              
         certain unidentified travel purposes 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 local-             
         ity of travel, described by name of city or town or other similar            
         designation; and (4) the business purpose of each such expendi-              
         ture, i.e., the business reason for the travel or the nature of              





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