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$2,250 is attributable to meals. Petitioner computed the vehicle
expenses by applying the then standard mileage rate of $.275 per
mile to the 30,000 miles he claims that he drove to attend job
interviews at various locations.
All of these expenses are subject to the strict
substantiation requirements imposed by section 274(d).
Deductions for expenses subject to section 274(d) are not allowed
"unless the taxpayer substantiates by adequate records or by
sufficient evidence corroborating the taxpayer's own statement
(A) the amount of such expense or other item, (B) the time and
place of the travel, * * * [and] (C) the business purpose of the
expense or other item". Petitioner claims that he recorded all
of the trips that he took to attend job interviews on a calendar
that was offered into evidence but excluded upon respondent's
objection. Because the calendar was not admitted into evidence,
it has not been taken into consideration. Furthermore, under the
circumstances, even if petitioner's calendar had been admitted
into evidence, it would have been given very little, if any,
weight.
Petitioner argues that he was not required to keep
substantiating records for meals and lodging expenses. According
to petitioner, he is entitled to claim the "government per diem"
amount for each location to which he traveled to attend a job
interview. It would appear that petitioner relies upon Rev.
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