Travel and entertainment expenses, as tax deductions, were the subject of sweeping changes in the Revenue Act of 1962. The enactment was Congress's answer to a problem which had troubled the Internal Revenue Service since the early forties. Shortly after the appearance of the new statute, the IRS laid out its own set of regulations on the same subject. The new rules, as enacted by Congress and supplemented by the Service, conveyed the message to American taxpayers that approximations in travel and entertainment deductions would no longer be allowed. The new rule: Substantiate the expenditure or face complete disallowance. The purpose of this article is to scrutinize the new statute and regulations and, from an historical standpoint, to ascertain the underlying reasons behind their promulgation. The rules will also be inspected in an analytical autopsy to determine whether they represent a fair and workable guide for claimants of T & E deductions.
IRS, Expense Accounts, and the Cohan Rule—An Exercise in Loophole Closing,
42 Neb. L. Rev. 644
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