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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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