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receipts or paid bills. Sec. 1.274-5T(c)(2)(i)-(iii), Temporary
Income Tax Regs., 50 Fed. Reg. 46017-46020 (Nov. 6, 1985).
Alternatively, taxpayers who are unable to satisfy the adequate
records requirement are still entitled to a deduction for expenses
that they can substantiate with other corroborative evidence. Sec.
1.274-5T(c)(3), Temporary Income Tax Regs., 50 Fed. Reg. 46020-
46021 (Nov. 6, 1985).
Petitioner claimed to have prepared a contemporaneous log or
diary to record her travel, meals, and entertainment during 1989.
However, petitioner refused to produce copies of these logs or
diaries. Because petitioner has clearly failed to meet the
adequate records requirement, we must determine whether she has
sufficiently substantiated her claimed travel and automobile
deductions with other corroborative evidence.
Petitioner deducted a total of $60 for parking at the
Sacramento airport. The only evidence offered to substantiate
these expenses was a parking receipt for $32 and petitioner's own
vague testimony that these parking expenses were incurred in a
business endeavor. We hold that petitioner failed to substantiate
these expenditures sufficiently.
Petitioner claimed a deduction in the amount of $53.90 for a
motel room. Petitioner produced a copy of a room receipt dated
June 30 as evidence of this expenditure. The receipt does not bear
the name or location of the motel. On brief, petitioner claimed
that the expenditure was for a motel in Klamath Falls, Oregon,
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