The case: A sales rep who traveled a lot to meet with clients and potential clients deducted a number of expenses. The IRS denied most of them.

Held: For the IRS. The taxpayer demonstrated that she traveled quite a bit in her car. To substantiate the expense deductions, the taxpayer submitted copies of her client contracts with handwritten notes estimating the miles driven to and from each location.

The court ruled that her proof was insufficient to meet the requirements of§274, Disallowance of certain entertainment, etc., expenses. The records did not establish the specific date of arrival and departure time for each trip, the name of events attended, clients met with or business discussed on each trip.

Despite the receipts for parking and toll expenses for each trip, there was no evidence that tied these expenses to particular business events, such as client meetings. The court said the expenses could easily have been incurred attending concerts or other personal activities. Nor did the taxpayer have contemporaneous records, such as a log or diary of her client meetings, to tie the expenses to the business activities.

For deduction of cell phone and internet expenses, the taxpayer provided only proof of amounts paid, not business use. She admitted that she and her daughter made personal use of the cell phones and internet. Because there was no log showing personal v. business use of the services, the taxpayer was not entitled to these deductions.

Armstrong v. Commissioner, T.C. Summ. Op. 2020-26]