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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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