James M. and Ruth J. Riley - Page 24

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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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