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The elements that a taxpayer must prove with respect to an
expenditure for traveling away from home on business, including
meals, are: (1) The amount of each such expenditure for
traveling away from home, except that the daily cost of the
traveler’s own breakfast, lunch, and dinner may be aggregated;
(2) the time of each such expenditure; i.e., the dates of
departure and return for each trip away from home and the number
of days away from home spent on business; (3) the place of each
such expenditure; i.e., the destinations or locality of travel,
described by name of city or town or other similar designation;
and (4) the business purpose of each such expenditure; i.e., the
business reason for the travel or the nature of the business
benefit derived or expected to be derived as a result of travel.
Sec. 1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg.
46014-46015 (Nov. 6, 1985). A taxpayer is required to
substantiate each element of an expenditure or use
* * * by adequate records or by sufficient evidence
corroborating his own statement. Section 274(d)
contemplates that a taxpayer will maintain and produce
such substantiation as will constitute proof of each
expenditure or use referred to in section 274. Written
evidence has considerably more probative value than
oral evidence alone. In addition, the probative value
of written evidence is greater the closer in time it
relates to the expenditure or use. A contemporaneous
log is not required, but a record of the elements of an
expenditure or of a business use of listed property
made at or near the time of the expenditure or use,
supported by sufficient documentary evidence, has a
high degree of credibility not present with respect to
a statement prepared subsequent thereto when generally
there is a lack of accurate recall. Thus, the
corroborative evidence required to support a statement
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