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the absence of corroborating evidence, we are not required to
accept the self-serving and unverified testimony of a taxpayer.
Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992); Tokarski
v. Commissioner, 87 T.C. 74, 77 (1986).
Moreover, section 274(d) provides that no deduction is
allowable under section 162 or 212 for any traveling expenses,
including meals and lodging while away from home, or with respect
to any listed property, defined in section 280F(d)(4) to include
property used as a means of transportation, unless the taxpayer
complies with strict substantiation rules. Sec. 274(d)(1), (4).
In particular, the taxpayer must substantiate the amount, time,
place, and business purpose of the expenses by adequate records
or by sufficient evidence corroborating his own statement. Sec.
274(d); sec. 1.274-5T(b)(2), (c), Temporary Income Tax Regs., 50
Fed. Reg. 46014, 46016 (Nov. 6, 1985).
Based on the limited record in this case, we find that
petitioners have failed to adequately substantiate petitioner's
alleged expenses in accordance with the requirements of section
274(d). We therefore hold that petitioners are not entitled to
deductions for expenses allegedly paid while petitioner worked in
Florida.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011