The Tax Court disallowed the deductibility of a minister's travel and transportation expenses because of a lack of substantiation.
The court observed that section 274(d) of the Internal Revenue Code specifies that travel and transportation expenses (including meals and lodging while away from home overnight) are not deductible unless a taxpayer substantiates by adequate records the amount of such expenses, the time and place of the travel, and the business purpose of the expenses.
In this case, the minister's receipts and records failed to substantiate all of these elements. For example, some receipts were for "oil and gas," but there was no proof that the oil and gas were used for business purposes.
The court acknowledged that the minister doubtless had been reimbursed by his church for some legitimate travel and transportation expenses that actually had been incurred. However, ...