Haron M. and Aurora L. Veras - Page 7

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          requirements for listed property as defined in section                      
          280F(d)(4), gifts, travel, entertainment, and meal expenses.                
          Sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014            
          (Nov. 6, 1985).  To obtain a deduction for a listed property,               
          travel, meal, or entertainment expense, a taxpayer must                     
          substantiate by adequate records or sufficient evidence to                  
          corroborate the taxpayer’s own testimony the amount of the                  
          expense, the time and place of the use, the business purpose of             
          the use and, in the case of entertainment, the business                     
          relationship to the taxpayer of each person entertained.  Sec.              
          274(d); sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed.               
          Reg. 46014 (Nov. 6, 1985).  Section 274 requires that expenses be           
          recorded at or near the time when the expense is incurred.  Sec.            
          1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016              
          (Nov. 6, 1985).  Listed property includes passenger automobiles.            
          Sec. 280F(d)(4)(A)(i).                                                      
               Petitioner presented very few documents to support the                 
          claimed business expense deductions.  Petitioner asserted that he           
          provided documents to the examining IRS agent, and that said                
          individual failed to return the substantiation presented.                   
          Respondent disputed this assertion, and respondent’s                        
          administrative file reflected that all substantiating documents             
          were returned to petitioners.  We are inclined to agree with                
          respondent’s version of these events.  The remarks in                       






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