Michael Kevin Boltinghouse - Page 20




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          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 and                      








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