8
percent of the total amounts of his invoices for worker's
compensation insurance for the years in issue.
3. Truck Expenses
Petitioner contends that he may deduct truck expenses for a
Ford truck that he bought in 1989 and used in his business.
Petitioner testified that he drove the truck about 100 miles a
day, 6 days a week, and that his use was purely for business.
However, petitioner offered into evidence no receipts or
documentation for any truck expenses. A taxpayer may not deduct
these expenses unless he or she substantiates by adequate records
or sufficient evidence corroborating the taxpayer's own statement
the amount, time and place, and business purpose of the expense.
Sec. 274(d)(4). Petitioner did not show that his truck was a
qualified nonpersonal use vehicle under section 274(d)(4),
274(i), and section 1.274-5T(k), Temporary Income Tax Regs., 50
Fed. Reg. 46033 (Nov. 6, 1985), which is exempt from the
substantiation requirements of section 274(d). We conclude that
petitioner may not deduct truck expenses for the years in issue.
4. Conclusion
Petitioner failed to carry his burden of proving that he is
entitled to deduct more than respondent allowed for the years in
issue.
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