- 6 -
46014 (Nov. 6, 1985), and requires strict substantiation of
expenses for travel, meals and entertainment, and gifts, and with
respect to any listed property as defined in section 280F(d)(4).
Sec. 274(d). Listed property includes any passenger automobile
or any other property used as a means of transportation, and
computers. Sec. 280F(d)(4)(A)(i), (ii), (iv).
A taxpayer is required by section 274(d) to substantiate a
claimed expense by adequate records or by sufficient evidence
corroborating the taxpayer’s own statement establishing the
amount, time, place, and business purpose of the expense. Sec.
274(d). Even if such an expense would otherwise be deductible,
the deduction may still be denied if there is insufficient
substantiation to support it. Sec. 1.274-5T(a), Temporary Income
Tax Regs., supra.
Respondent disallowed petitioner’s car and truck expense
deduction of $2,347. As stated above, section 274 requires
strict substantiation for deductions claimed for transportation
in a passenger car. At trial, petitioner testified that she used
the actual mileage to calculate the car and truck expense.
Petitioner’s car was used to commute to and from petitioner’s
full-time job and for other personal uses. Petitioner offered
automobile service documents to show the odometer readings for
the beginning and end of tax year 1997 but failed to provide a
mileage log noting how many miles she drove for her consulting
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011