Robert Thomas Walters - Page 5




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          short, petitioner has not met the substantiation requirements of            
          section 274(d).  Section 1.274-5T(a), Temporary Income Tax Regs.,           
          50 Fed. Reg. 46014 (Nov. 6, 1985), provides that a taxpayer shall           
          not be allowed a deduction based on approximation or the                    
          taxpayer’s unsupported testimony.  Accordingly, we hold that                
          petitioner is entitled to a mileage deduction limited to the                
          miles set forth on the job worksheets.                                      
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          

























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