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Petitioner also testified that on certain days, he "had to"
travel an additional distance to Concord and to Pleasant Hill,
California, to pick up Ro-Tile's payroll and return to Ro-Tile.
On each of those occasions, according to petitioner, he would
visit a "hamburger joint" called Fuddruckers located in Concord.
For that reason, petitioner stated that he made the notation
"FUDD" on calendar days when he went to Concord. Petitioner gave
no testimony on the additional distance he traveled on "FUDD", or
payroll, days. He did supply an adding machine tape on which
several entries of various amounts of mileage are added to
produce the sum of 2,757. No other explanation or evidence was
provided for the "FUDD" trips.
Section 274(d)(4) and the regulations thereunder call for
substantiation of "each element" of every business use of listed
property. The level of detail required for adequate
substantiation, however, depends on the facts and circumstances
of each case. Where the taxpayer makes regular trips to a fixed
location, he may satisfy the adequate record requirement by
recording the total number of miles driven, the length of the
route once, and the date of each trip at or near the time of the
trips. Sec. 1.274-5T(c)(2)(ii)(C), Temporary Income Tax Regs.,
supra.
Petitioners failed to provide an adequate record of
substantiation or other sufficient evidence for the 2,757 miles
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