Such strict adherence to the substantiation requirements was on display again yesterday in Evenchik v.
Villareale is a timely reminder about one of the most absolute substantiation requirements in the Code.
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You must comply with any substantiation requirements, regardless of how onerous they may seem.
But when a simple request for substantiation or documents looks like legal process, stress levels go higher still.
The lack of substantiation for the alleged facts should serve as a caution.
Apart from enhanced substantiation rules, the problem with entertainment is that it limits some deductions to 50% of what you spend.
Should they have pressed harder for substantiation before holding him this long?
Yet the IRS said Mr. Mohamed failed to comply with the appraisal and substantiation rules and the Tax Court had to agree.
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But L'Oreal said both commercials had been approved by the Broadcast Advertising Clearance Centre on the basis of the "technical substantiation of the product benefits".
This area of tax law requires substantiation and can be tricky.
What would the AGs accept as substantiation for a health claim?
"The reputation and safety of a player is also paramount and to suggest anything untoward without any substantiation or firm evidence is irresponsible and most unfair on a player, " he said.
Whatever the motivation, this inflation in reporting has the negative consequence of inflating future rights fees charged while creating doubt in the veracity of organizations that routinely report biased numbers without substantiation.
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The cellphone substantiation provision was needed because the Internal Revenue Service has strict, congressionally ordered rules requiring proof you made a donation if you want to take it as a tax deduction.
And you need to have the substantiation letter from the charity on or before the earlier of the date you file your return or the due date (including extensions) for filing the return.
There was a quite a bit about substantiation and the Cohan rule in the case, but the most important element is the application of Code Section 280E (Expenditures in Connection With The Illegal Sale of Drugs).
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The ASA says it doesn't wish to "disregard anyone's beliefs, but specific claims targeted at people who may be seriously ill must comply with the rules on substantiation and social responsibility that apply to all other advertising".
Also, they gave him good marks for keeping thorough records, but they saw the goal of his record keeping to be focused on substantiation of tax deductions rather than on getting good information to correct his business plan.
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The Cohan Rule is most classically applied to travel and entertainment, but can apply to virtually any item not specifically subject to heightened substantiation requirements (such as certain travel and meal expenses, passenger automobiles, computers and cell phones).
According to Mr Fitzgerald's summation, Mr Libby claimed, to the FBI and under oath to the grand jury, to be at the end of a gossip chain, passing what he heard from reporters on to other reporters without substantiation.
There is, however, no substantiation of these claims offered to say nothing of any evidence that the proposed action will produce either a more effective or less costly means of meeting continuing requirements for support to the U.S. nuclear forces.
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