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ties involved. See sec. 274(d); sec. 1.274-5T(a), Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
The recordkeeping requirements of section 274(d) will
preclude petitioner from deducting expenditures otherwise allow-
able under section 162(a)(2) relating to the use of his automo-
bile, for travel, for meals, and for entertainment unless he
substantiates the requisite elements of each such expenditure or
use. See sec. 274(d); sec. 1.274-5T(b)(1), Temporary Income Tax
Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). A taxpayer is required
to
substantiate each element of an expenditure or use
* * * by adequate records or by sufficient evidence
corroborating his own statement. Section 274(d) con-
templates that a taxpayer will maintain and produce
such substantiation as will constitute proof of each
expenditure or use referred to in section 274. Written
evidence has considerably more probative value than
oral evidence alone. In addition, the probative value
of written evidence is greater the closer in time it
relates to the expenditure or use. A contemporaneous
log is not required, but a record of the elements of an
expenditure or of a business use of listed property
made at or near the time of the expenditure or use,
supported by sufficient documentary evidence, has a
high degree of credibility not present with respect to
a statement prepared subsequent thereto when generally
there is a lack of accurate recall. Thus, the corrobo-
rative evidence required to support a statement not
made at or near the time of the expenditure or use must
have a high degree of probative value to elevate such
statement and evidence to the level of credibility
reflected by a record made at or near the time of the
expenditure or use supported by sufficient documentary
evidence. The substantiation requirements of section
274(d) are designed to encourage taxpayers to maintain
the records, together with documentary evidence, as
provided in paragraph (c)(2) of this section [1.274-5T,
Temporary Income Tax Regs.].
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