Lorenzo Battle - Page 13

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          Since petitioner did not provide any other substantiation, he is            
          not entitled to deductions for car and truck expenses.                      
                    b.   Meals and Entertainment Expenses                             
               Petitioner claimed deductions of $1,250 for meals and                  
          entertainment expenses, before the application of section 67.               
          Petitioner indicated on the spreadsheet that he paid $466.09 for            
          meals in connection with Zomans Productions.  Petitioner contends           
          that he met regularly with four or five clients.  Petitioner                
          presented a 2002 calendar which he claims noted the dates when he           
          took a client to lunch or dinner.  The calendar, however, did not           
          make any cross-references to the spreadsheet, and the Court is              
          therefore unable to determine when the expenses were paid.                  
          Moreover, the calendar failed to specify, as required by the                
          regulations, who the clients were, the nature of the clients’               
          business relationship with petitioner, the business purpose of              
          the meals, and the locations of the meals.  See sec. 1.274-                 
          5T(b)(3), (c), Temporary Income Tax Regs., 50 Fed. Reg. 46015,              
          46016 (Nov. 6, 1985).                                                       
               The Court finds that the evidence petitioner presented is              
          insufficient to satisfy the strict substantiation requirements of           
          section 274(d).  Since petitioner did not provide any other                 
          substantiation, he is not entitled to deductions for meals and              
          entertainment expenses.                                                     







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