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evidence corroborating the taxpayer's own statement. At a
minimum, the taxpayer must substantiate: (1) The amount of such
expense, (2) the time and place such expense was incurred, and
(3) the business purpose for which such expense was incurred.
Section 274(d)(4) also provides that no deduction is
allowable with respect to listed property, as defined in section
280F(d)(4), unless the deductions are substantiated in accordance
with the strict substantiation requirements of section 274(d) and
the regulations promulgated thereunder. Passenger automobiles
are included in the definition of listed property in section
280F(d)(4). Sec. 280F(d)(4)(A)(i).
To substantiate a deduction attributable to listed property,
a taxpayer must maintain adequate records or present
corroborative evidence to show: (1) The amount of the expense,
(2) the time and place of the use of the listed property, and (3)
the business purpose for the use. Sec. 1.274-5T(b)(6), Temporary
Income Tax Regs, 50 Fed. Reg. 46016 (Nov. 6, 1985).
In order to substantiate a deduction by means of adequate
records, a taxpayer must maintain a diary, a log, or a similar
record, and documentary evidence, which, in combination, are
sufficient to establish each element of each expenditure or use.
Sec. 1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg.
46017 (Nov. 6, 1985). To be adequate, a record must generally be
written. Each element of an expenditure or use that must be
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