Steven and Jennie Jacobs - Page 8

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            discretion may prescribe rules waiving such requirements in                                   
            circumstances where he determines it is impracticable for such                                
            documentary evidence to be required."  Sec. 1.274-5T(c)(2)(iii)                               
            (B), Temporary Income Tax Regs., 62 Fed. Reg. 13990 (Mar. 25,                                 
            1997).                                                                                        
                  "Listed property", the use of which for transportation                                  
            purposes must meet the substantiation requirements of section                                 
            274(d)(4), includes passenger automobiles and trucks.  Sec.                                   
            280F(d)(4)(A)(i) and (ii); sec. 1.280F-6T(b)(2)(i), Temporary                                 
            Income Tax Regs., 49 Fed. Reg. 42713 (Oct. 24, 1984).  However,                               
            section 1.274(d)-1, Income Tax Regs., authorizes the Commissioner                             
            to prescribe rules for mileage allowances for ordinary and                                    
            necessary expenses for local transportation, see Dehr v.                                      
            Commissioner, T.C. Memo. 1998-441, and such rules were prescribed                             
            for the year 1992.  See Rev. Proc. 91-67, 1991-2 C.B. 887.                                    
            1.    Advertising Expense of $2,500                                                           
                  Petitioner claimed and testified that he paid a total of                                
            $2,500 in cash for advertising his advertising business at the                                
            rate of $100 per ad in two local publications published monthly                               
            by Matson Publications, "Nevada Today" and "Nevada Woman".                                    
            Petitioner provided no invoices, no copies of the ads, and no                                 
            other witness who established that the ads were placed.                                       
            Subsequent to trial, he failed to produce copies of the ads,                                  
            either from his retained boxes of records, or from the Reno                                   





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