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Since it is uncontested that petitioner's home office was
his principal place of business, we find that car and truck
expenses shown to have been incurred by petitioner in traveling
between his business office in his home and other business
locations are business expenses. See Walker v. Commissioner, 101
T.C. 537, 545 (1993); Wicker v. Commissioner, T.C. Memo. 1986-1.
Substantiation
Petitioners must show that the amounts claimed are
deductible business expenses. Rule 142(a); New Colonial Ice Co.
v. Helvering, 292 U.S. 435, 440 (1934); Hradesky v. Commissioner,
65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.
1976).
Failure to prove the exact amount of an otherwise deductible
item may not always be fatal, because generally, unless precluded
by section 274, we may estimate the amount of such an expense and
allow the deduction to that extent. Finley v. Commissioner, 255
F.2d 128, 133 (10th Cir. 1958), affg. 27 T.C. 413 (1956); Cohan
v. Commissioner, 39 F.2d 540, 554 (2d Cir. 1930).
Section 274(d) provides, however, that no deduction shall be
allowed with respect to any "listed property", as defined in
section 280F(d)(4), unless the taxpayer substantiates by adequate
records or sufficient evidence to corroborate the taxpayer's own
testimony: (1) The amount of the expenditure or use based on the
appropriate measure (mileage may be used in the case of
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