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section 6653(a), the predecessor to section 6662(a). The Court,
however, emphasized the extensive and detailed business records
maintained by the taxpayer. Robinson v. Commissioner, supra at
542. In contrast, petitioner in the instant case produced no
records to support the deductions claimed on his Schedule C for
office expenses and dues and subscriptions. Furthermore, with
regard to the claimed automobile expense, petitioner's concept of
what constitutes adequate record keeping is at odds with the
substantiation requirements of section 274 and the regulations
thereunder.6
We conclude that petitioner failed to keep adequate records,
and in turn was unable to provide his accountant with all the
necessary and relevant information. Therefore, we sustain
respondent's determination of the accuracy-related penalty under
6 The records petitioner provided to his accountant in support
of the automobile expense fall far short of the requirements of
the Code and regulations. A passenger automobile is defined as
"listed property" under sec. 280F(d)(4)(A)(i), and thus is
subject to the substantiation requirements of sec. 274(d). Among
the elements required to be substantiated are the amount of
business use and the amount of total use of the automobile for
the taxable period, based upon mileage. Bradley v. Commissioner,
T.C. Memo. 1998-170; sec. 1.274-5T(b)(6)(i)(B), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). The record
reflects that the total mileage figure for 1994 was based upon
odometer readings noted on repair receipts from May and June
1993, a different year from that in issue here; from these
readings, petitioner's accountant extrapolated an estimated
annual mileage figure for the automobile for 1994. Moreover,
petitioner's business use of the automobile was estimated from a
log covering only 1 month in 1994, rather than the full year.
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