Sanford v. Commissioner
United States Tax Court
T maintained a "diary" in which he recorded alleged business entertainment expenditures for which he received no reimbursement from his employer. He did not either obtain or retain receipts or other corroborating documentary evidence with respect to such expenditures. Held: The Commissioner properly disallowed deduction for all such expenditures of $ 25 or more. Sec. 1.274-5(c)(2), Income Tax Regs., supporting such action, is valid.
1Opinion of the Court
OPINION
Raum, Judge:
Petitioner, an outside salesman of television-advertising time, claimed $8,853.35 entertainment expenses on Form 2106— “Statement of Employee Business Expenses,” which was made part of his 1963 income tax return (Form 1040). This sum, according to petitioner’s testimony, represented the cost of luncheons and dinners during 1963 at which petitioner discussed business with “advertising agency people.” He was either advanced or reimbursed for the cost of some of those meals by his employer, and the Commissioner does not challenge the propriety of such expenses here. The…
2Cases cited9 opinions
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