7 substantiate the amount of each separate expenditure, the amount of business and total use of the property, the date of the expenditure or use, and the business purpose for the expenditure or use. Sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). Based on the mileage reported on petitioner's reimbursement expense reports, on brief respondent concedes that petitioner is entitled to a deduction for automobile expenses in the amount of $827.94 using the standard mileage rate. Respondent contends that petitioner has failed to substantiate automobile expense in excess of this amount. We agree. It is clear that petitioner paid some automobile insurance premiums during 1989. She provided evidence of insurance expense in the amount of $1,740.61. Petitioner has not established any amount paid for the lease of her car. Petitioner testified that she claimed 95 percent of her automobile expense as attributable to business usage of her car. However, petitioner maintained no records which would indicate that the business usage of her car was 95 percent. Petitioner has not met the requirements of substantiation under section 274(d). Accordingly, she is not entitled to a deduction for automobile expense in excess of the amount conceded by respondent. Petitioner contends that she is entitled to a deduction in the amount of $1,155 for expense incurred with respect to the use of a computer in her work for Pitney Bowes. Petitioner testifiedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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