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Petitioner also claimed certain travel expense deductions for
business-related travel and automobile expense deductions, which
respondent has disallowed. Section 162(a)(2) allows a deduction
for all ordinary and necessary travel expenses paid by a taxpayer
during the taxable year while traveling away from home in pursuit
of a trade or business. A travel expense deduction is disallowed
if the taxpayer does not satisfy the substantiation requirements of
section 274(d) through either adequate records or the taxpayer's
own detailed statement that is corroborated by sufficient evidence.
Section 274(d) also applies to listed property, which includes any
passenger automobile. Secs. 274(d)(4), 280F(d)(4)(A)(i). At a
minimum, the taxpayer must substantiate: (1) The amount of the
expense, (2) the time and place such expense was incurred, (3) the
business purpose of the expense, and (4) the business relationship
to the taxpayer of any persons entertained. Sec. 274(d).
The regulations further clarify the stringent substantiation
requirements of section 274. A taxpayer generally must
substantiate each expenditure by producing (1) adequate records or
(2) sufficient evidence to corroborate his or her own statement.
Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
46016-46017 (Nov. 6, 1985). The "adequate records" standard
requires that a taxpayer maintain an account book, diary, log,
statement of expense, or other similar record that contains entries
of expenditures made at or near the time of the expenditure. In
addition, a taxpayer must supply documentary evidence, such as
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