Howard K. Hager - Page 9




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          sufficient corroborative evidence, then it is disallowed.  See              
          sec. 274(d).                                                                
               In order to substantiate amounts expended for travel, the              
          taxpayer must prove the:  (1) Amount of each expenditure (i.e.,             
          lodging, meals, gas, and etc.); (2) time (i.e., dates of                    
          departure and return trip and number of days spent on business);            
          (3) place; and (4) business purpose (i.e., the business reason              
          for the travel or the nature of the business benefit to be                  
          derived).  See sec. 1.274-5T(b)(2)(i) through (iv), Temporary               
          Income Tax Regs., supra.                                                    
               Similarly, in order to substantiate amounts expended for               
          entertainment, the taxpayer must prove the:  (1) Amount of each             
          expenditure (except for incidental items such as taxi fares or              
          telephone calls that may be aggregated on a daily basis);                   
          (2) time, which means the date of the entertainment; (3) place              
          (i.e., the name, if any, address or location, and designation of            
          the type of entertainment, such as dinner or theater, if it is              
          not apparent from the designation of the place); (4) business               
          purpose (i.e., the business reason for the entertainment or the             
          nature of the business benefit to be derived and the nature of              
          the business discussion or activity); and (5) business                      
          relationship (i.e., name, title, occupation, or similar                     
          information of the persons entertained).  See sec.                          








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