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regulations that allow a taxpayer to reconstruct his records,
citing section 1.274-5T(c)(4) and (5), Temporary Income Tax
Regs., 50 Fed. Reg. 46006, 46021-46022 (Nov. 6, 1985). The Court
notes, however, that petitioner's records were lost, through
theft, for only a portion of the year at issue, and only the
airplane FAA log and some of the receipts relating to the
airplane were so lost. Petitioner suffered no such loss of
records with respect to the other expenses at issue, nor were
such records lost as to the airplane for the remainder of 1992.
The Court, therefore, considers whether the records petitioner
submitted that were not lost and, therefore, were not
reconstructed pass muster under section 274(d). The records
submitted do not satisfy the record-keeping requirements of
section 274(d) for several reasons. Most notably, petitioner did
not maintain a contemporaneous record of the expenses, at or near
the time they were incurred. Perhaps the most important element
of the record-keeping requirement is the contemporaneous
maintenance of a log, chronicling each event in which an expense
is incurred and corroborating that expense with receipts or other
documents evidencing that the expense was incurred. The
documentation submitted by petitioner fails to satisfy this
requisite. Although petitioner submitted numerous cash and
credit card receipts, most of these receipts bear no information
tying the receipt to an event or an expense. The reconstructed
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