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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 testified
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