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Petitioner contends that she incurred car and truck expenses
as the result of her commutes to the SSA located in Baltimore,
Maryland. At trial, petitioner estimated that she made 156 trips
in 1992, averaging three or four trips a week. Using the 1992
standard mileage rate of 28 cents, we calculated that petitioner
purportedly traveled about 25,039 miles ($7,011 � 28 cents).
After a review of the record, we find that the record lacks
any documentary evidence to support petitioner's claimed car and
truck expenses. Petitioner failed to maintain adequate records
such as a diary, log book, or trip sheets to evidence the
distances she purportedly traveled in furtherance of her medical
practice. Indeed, petitioner admitted that she "didn't keep a
log" of her trips to Baltimore. Under the strict substantiation
rules of section 274(d), we hold that petitioner is not entitled
to deduct car and truck expenses for 1992.
With respect to insurance, mortgage interest, office
expense, repairs and maintenance, travel, utilities, secretarial,
medical books, dues, conferences, and security system, petitioner
introduced into evidence copies of receipts, invoices, billing
statements, and estimate worksheets in support of her claimed
deductions. On this record, the Court believes that petitioner
was seeking to deduct many expenses that are personal, living, or
family expenses which are nondeductible under section 262.
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