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Travel
Petitioners contend that the $9,615 claimed for traveling
expenses was for trips to Hawaii, Korea, China, Las Vegas, and
Chicago, for the purpose of locating potential real estate
investment opportunities for petitioner’s clients. With the
exception of expenses for airfare to Hawaii and Chicago, a rental
car in Hawaii, lodging in Hawaii and Las Vegas, and a few
incidental traveling expenses, petitioners contend that they paid
the traveling expenses in cash. In support of these expenses,
petitioners offered airline receipts, a few credit card
statements, and two taxi cab receipts.
Although section 162(a) expressly permits a deduction for
traveling expenses away from home in the pursuit of a trade or
business, section 274(d) imposes strict substantiation
requirements for deductions related to traveling expenses. A
deduction for traveling expenses demands, pursuant to section
274(d), that the taxpayer substantiate by adequate records or by
sufficient evidence the amount of the expense, the time and place
of the travel, and the business purpose of the expense. On the
record, the Court holds that petitioners’ limited receipts and
lack of evidence to corroborate their own statements fail to
satisfy the strict substantiation requirements of section 274(d).
See sec. 274(d); sec 1.274-5T(b)(2), Temporary Income Tax Regs.,
50 Fed. Reg. 46014 (Nov. 6, 1985). Despite petitioner’s
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