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Petitioner testified that, until the first half of 2000, he
was “still trying to raise other funds, get other investors, get
Kirshner back in the fold, deal with this investor that was
having an issue with Kirshner”. According to petitioner, these
expenses, consisting of office supplies, meals, and travel, were
all incurred on behalf of the entire Kirshner enterprise during
the year 2000.
Petitioner’s Schedule C of his 2000 Federal income tax
return included the following other expenses:
Supplies $ 139.50
Travel 1,050.00
Meals and entertainment
(deductible portion) 347.64
Total $1,537.14
As to meals, entertainment, and travel expenses, section
274(d) imposes stringent substantiation requirements for
deductions related thereto. For travel expenses, including meals
and lodging, a taxpayer must substantiate: (1) The amount of
such expense; (2) the time and place such expense was incurred;
and (3) the business purpose for which such expense was incurred.
Sec. 1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg.
46014 (Nov. 6, 1985). Section 274(d) specifically bars a
taxpayer from claiming a deduction on the basis of any
approximation or the unsupported testimony of the taxpayer. Sec.
1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov.
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