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we allow depreciation with respect to these particular items in
question.
Petitioner purchased a Toyota Previa van for his company for
$23,038.50 from Thomason Toyota. He bought the van in Oregon.
He also expended $670.60 to ship the van to Hawaii from the
mainland. Petitioner stated that the van was strictly utilized
for business purposes. Ultimately, however, petitioner did not
meet the standard required by section 274 to show the vehicle's
business usage. See sec. 1.274-5T(a), Temporary Income Tax
Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). With respect to the
remaining expenditures, petitioner's testimony was vague and
self-serving. For example, according to petitioner's testimony,
and the canceled checks submitted for the record, he purchased
various pieces of office equipment in 1991. However, petitioner
has failed to substantiate the extent to which office equipment,
such as chairs from Ushijima, was used in his trade or business.
Petitioner was also unable to recollect the reasons for the
amounts paid to Sears, Shirokiya, and American Express. As
petitioner has failed to specify the business purpose of these
particular expenses, we sustain respondent's determination
disallowing these deductions.
C. Travel Expense Deduction
Petitioner claimed a travel expense deduction in the amount
of $19,027 on Schedule C of his 1991 Federal income tax return.
Respondent disallowed this deduction in its entirety in the
statutory notice of deficiency.
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