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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 petitioner
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