- 20 - taxpayer must provide adequate records or corroborating evidence showing the costs of the gifts, the dates the gifts were made, descriptions of the gifts, the business purposes of the gifts, and the business relationships between the taxpayer and the gift recipients. Sec. 274(d); sec. 1.274-5T(b)(5), (c), Temporary Income Tax Regs., 50 Fed. Reg. 46016-46017 (Nov. 6, 1985). Petitioner introduced no evidence showing the dates of the gifts and provided only vague, uncorroborated testimony regarding the business purposes of the gifts and his relationships with the recipients. Therefore, we agree with respondent that petitioner is not entitled deduct the costs of the business gifts for 2003. 3. Entertainment and Business Meals Under section 274(d)(2), a taxpayer may not claim a deduction for entertainment expenses unless the taxpayer meets the strict substantiation requirements. To substantiate such an expenditure, a taxpayer must provide adequate records or have sufficient evidence corroborating the amount of the expenditure, the date of the entertainment, the location of the entertainment, the business purpose of the entertainment, and the business relationship between the taxpayer and the person entertained. Sec. 1.274-5T(b)(5), Temporary Income Tax Regs., supra. Petitioner asserts that he is entitled to a deduction of 50 percent of $977, which he allegedly spent on meals andPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: November 10, 2007