Edward M. Fontanilla - Page 8




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          unconvincing.  Petitioner, therefore, has failed to prove the                
          value of this contribution.  Using our judgment, we find that the            
          fair market value of the donated property was $15.  Thus,                    
          petitioner is entitled to a deduction in this amount.  See Cohan             
          v. Commissioner, supra; Zmuda v. Commissioner, supra.                        
          Issue 3.  Transportation Expenses                                            
               Petitioner claimed a deduction of $3,750 for unreimbursed               
          employee travel expenses for the miles that he drove between                 
          hospitals on the days that he worked at more than one hospital.3             
               Section 274(d) imposes stringent substantiation requirements            
          for the deduction of travel expenses, entertainment expenses,                
          gift expenses, and expenses of certain listed property defined               
          under section 280F(d)(4) such as an automobile.  See sec.                    
          274(d)(1); sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed.             
          Reg. 46014 (Nov. 6, 1985).  If an expense item comes within the              
          requirements of section 274(d), this Court cannot rely on Cohan              
          v. Commissioner, supra, to estimate the taxpayer's expenses with             
          respect to that item.  See Sanford v. Commissioner, 50 T.C. 823,             
          827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969); sec.               
          1.274-5T(a)(4), Temporary Income Tax Regs., 50 Fed. Reg. 46014               
          (Nov. 6, 1985).                                                              



               3Petitioner reported that he drove 12,500 business miles and            
          claimed the standard mileage deduction of 30 cents per mile.                 




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