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also drove to the library where she would listen to music in
connection with her performances. Mrs. Popov would make a note
in her calendar when she would go to the library.
Mrs. Popov measured the distance the first two or three
times she drove to a particular location. Using Mrs. Popov’s
calendar, petitioners constructed a mileage log to assist them in
preparing their tax return. The log listed the date,
destination, and round-trip mileage for each trip. According to
their return, Mrs. Popov drove 11,950 miles in 1993 and took the
mileage deduction of $3,346 based on 28 cents per mile.3 See
Rev. Proc. 92-104, 1992-2 C.B. 583, 584.
In order to deduct an automobile expense under section
162(a), petitioners must comply with the strict substantiation
requirements under section 274(d). Section 274(d)(4) requires
substantiation for certain items listed under section 280F(d)(4)
such as passenger automobiles. Sec. 280F(d)(4)(A)(i). In order
to substantiate a deduction attributable to listed property, a
taxpayer must maintain adequate records or present corroborative
evidence to show: (1) The amount of each automobile expenditure,
(2) the automobile’s business and total usage, (3) the date of
the automobile’s use, and (4) the business purpose of the
automobile trip. Sec. 1.274-5T(b)(6), Temporary Income Tax
Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
3 We note a small discrepancy as the total number of miles
listed in the log is 11,750.
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