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16,125.69 miles traveled in petitioner's vehicles for Eagle
during 1994. Petitioner offered no additional evidence to
substantiate the remaining 28,874.31 miles that she claimed in
computing her deduction. Consequently, we hold that petitioner
is entitled to a further deduction for 1994 only to the extent
that a mileage deduction computed on the basis of 16,125.69 miles
exceeds the amount already allowed by respondent as a deduction
for business mileage.
Meals and Travel
On the Schedule C attached to her 1993 return, petitioner
claimed $1,380 as a deduction for travel, meals, and
entertainment. Respondent denied those deductions for lack of
substantiation under section 274(d). As with her claimed mileage
for 1993, petitioner claims that all of her 1993 records were
destroyed by the Flint River flood. Although the destruction
caused by the flood excuses petitioner from certain of the
rigorous requirements of section 274(d), petitioner failed to
make a reasonable reconstruction of those records pursuant to
section 1.274-5T(c)(5), Temporary Income Tax Regs, supra.
Consequently, we cannot allow her a deduction for those expenses.
On the Schedule C attached to her 1994 return, petitioner
claimed $803 as a deduction for travel, meals, and entertainment.
Section 1.274-5T(c)(2)(iii), Temporary Income Tax Regs., 50 Fed.
Reg. 46019 (Nov. 6, 1985), provides:
(iii) Documentary evidence. Documentary evidence,
such as receipts, paid bills, or similar evidence
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