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and maintenance bills, and a letter from his automobile insurance
provider noting the annual premium. McDonald testified that,
during 1989, he drove his automobile 8,000 miles, 90 percent of
which represented business miles.
Under section 274(d), taxpayers are required to meet certain
substantiation requirements in order to be entitled to a
deduction for certain business expenses. Section 274(d)(4)
(which is effective for taxable years beginning on or after
January 1, 1986) requires substantiation for a taxpayer to be
entitled to deduct travel expenses. McDonald’s substantiated
expenditures connected with his automobile for the 1989 year
exceed the total of the $250 monthly payments received from Gold.
McDonald offered no records or other evidence, however, of the
business use of his automobile other than his testimony, which
was expressed in terms of a rough estimate without any meaningful
detail or contemporaneous support. McDonald has not met the
section 274(d) requirements necessary to show entitlement to
transportation deductions, and, accordingly, respondent’s income
determination regarding the monthly payments from Gold is
sustained. Rule 142(a).
Maynard and McDonald both contend that the remainder of
payments from Gold to petitioners is attributable to Maynard,
even though $6,024 of the checks was written to McDonald from
Gold’s Bank of Lodi account. Petitioners, here again, bear the
burden of showing error regarding respondent’s determination that
$6,024 is income to McDonald and $20,421 is income to Maynard.
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