James G. LeBloch and Cathy Michelsen LeBloch - Page 34




                                        -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).                                                        










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