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establish each element of expenditure or use. Sec. 1.274-
5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov.
6, 1985). Each element of an expenditure or use that must be
substantiated should be recorded at or near the time of that
expenditure or use. Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income
Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Travel and car and
truck expenses cannot be estimated under Cohan. Sanford v.
Commissioner, 50 T.C. 823, 827-828 (1968), affd. per curiam 412
F.2d 201 (2d Cir. 1969).
On his 1997 Schedule C, petitioner deducted total car and
truck expenses of $4,123. Petitioner also claimed a depreciation
expense deduction of $1,396 with respect to the business use of
his vehicle.
After a review of the record, we find that petitioner failed
to maintain adequate records such as a diary, log book, or trip
sheets to show the distances he purportedly traveled in
furtherance of his “investor” business. Petitioner’s mileage
summaries are insufficient because the mileage amounts were not
entered at the time the vehicles were used. Therefore, under the
strict substantiation rules of section 274(d)(4), we hold that
petitioner is not entitled to deduct any car and truck expenses
for 1997. Accordingly, respondent’s disallowance of petitioner’s
Schedule C deduction for car and truck expenses is also sustained
on this ground.
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