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however, that no deductions shall be allowed: (1) For any
traveling expense, including meals and lodging while away from
home, (2) for any item with respect to an activity which is of a
type generally considered to constitute entertainment, amusement,
or recreation, (3) for any expense for gifts, or (4) with respect
to any "listed property" as defined in section 280F(d)(4), unless
substantiated in accordance with the strict requirements of
section 274(d) and the regulations promulgated thereunder.
Included in the items defined as listed property in section
280F(d)(4) is any passenger automobile. Sec. 280F(d)(4)(A)(i).
To substantiate a deduction under section 274(d), a taxpayer
must maintain adequate records or present other corroborative
evidence to show, among other things, the business purpose and
business relationship of the expense. Sec. 1.274-5T(b),
Temporary Income Tax Regs., 50 Fed. Reg. 46014-46016 (Nov. 6,
1985).
In order to substantiate a deduction by means of adequate
records, a taxpayer generally 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, including business purpose and relationship. Sec. 1.274-
5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017
(Nov. 6, 1985).
Although petitioner produced various receipts and charts in
support of her deductions for unreimbursed employee business
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