- 11 - substantiated should be recorded at or near the time of that expenditure or use. Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Thus, under section 274(d), and as with travel expenses, no deduction may be allowed for expenses incurred for the use of a passenger automobile on the basis of any approximation or the unsupported testimony of the taxpayer. E.g., Golden v. Commissioner, T.C. Memo. 1993-602. Research Expenses Petitioner claimed a Schedule A deduction for research expenses in the amount of $4,125, of which respondent has conceded $3,443.89. Of the remaining amount ($681.11), $343.20 relates to petitioner's claim that she is entitled to a deduction for more mileage than respondent allowed; $108 pertains to petitioner's contention that section 274(n) does not pertain to her meals expenses; and $229.91 pertains to miscellaneous expenses. With regard to the mileage expense, petitioner drove from Rochester, New York, to Portland, Oregon, to attend the Second International Family Nursing Conference. Based upon a stipulated Rand McNally mileage chart, respondent conceded that petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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