Mila Alemasov and Victor Popov - Page 17




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          place, and business purpose of the expenditure and must provide             
          adequate records or sufficient evidence to corroborate the                  
          claimed expense.  Sec. 274(d); sec. 1.274-5T(c)(1), Temporary               
          Income Tax Regs., supra.  In order to meet the “adequate records”           
          requirement, a taxpayer must maintain an account book, diary,               
          statement of expenses, or similar record and documentary evidence           
          (such as receipts, paid bills, or similar evidence) which, when             
          combined, establish each element of the expense that section                
          274(d) requires to be established.  Sec. 1.274-5T(c)(2)(i),                 
          Temporary Income Tax Regs., supra.  Petitioners’ credit card                
          statements and the spreadsheet that was created after the year at           
          issue do not meet the adequate records requirement for meals and            
          entertainment expenses of section 274(d) and the regulations                
          because they fail to sufficiently corroborate petitioners’ own              
          statements.  Id.  Since petitioners did not provide the required            
          substantiation for these expenses, they are not entitled to the             
          deduction for meals and entertainment expenses.                             
          Other Expenses                                                              
               Petitioners claimed a deduction of $3,585 for other                    
          expenses, including books, postage, printing, Internet access at            
          Kinko’s, and other items.  Aside from monthly credit card                   
          statements and nonitemized credit card receipts, petitioners                
          offered no documentary evidence to support the claimed expenses.            
          Additionally, petitioners did not establish that these expenses             







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