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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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