-34- (1960). Second, the taxpayer must substantiate, by adequate records or other sufficient evidence corroborating his or her own statement, each of the following elements: (1) The amount of each expenditure; (2) the time and place the expenditure was incurred; (3) the business purpose of the expenditure; and (4) in the case of entertainment expenses, the business relationship to the taxpayer of the person entertained. See sec. 274(d); Meridian Wood Prods. Co. v. United States, 725 F.2d 1183, 188-1191 (9th Cir. 1984); Johnston v. Commissioner, T.C. Memo. 1980-477, affd. 696 F.2d 1003 (9th Cir. 1982). In the case of meals incurred while not traveling, substantiation by sufficient evidence requires that the taxpayer establish the cost, amount, time, place, and date of the expenditure by “direct evidence” (e.g., a detailed writing); the taxpayer may establish business purpose or business relationship by “circumstantial evidence” corroborating the taxpayer’s own statement. Sec. 1.274-5T(c)(3)(i), Temporary Income Tax Regs., 49 Fed. Reg. 42704 (Oct. 24, 1984). 1. 1997 Of the Schedule C expenses disallowed for 1997, petitioners challenge only the expenses for travel (to the extent of $5,978) and other ($18,719).Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: November 10, 2007