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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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