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In order to claim deductions, taxpayers must substantiate by
adequate records certain items such as the amount and place of
each separate expenditure, the property's business and total use,
the date of the expenditure or use, and the business purpose for
an expenditure or use. See sec. 274(d); sec. 1.274-5T(b),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
In addition, section 274(d)(1) requires the same substantiation
for any deduction claimed "under section 162 or 212 for any
traveling expense".
To substantiate a deduction by means of adequate records, a
taxpayer generally must maintain an account book, diary, log,
statement of expense, trip sheets, or similar record, and
documentary evidence which, in combination, are sufficient to
establish each element of each expenditure or use, including
business purpose and relationship. See sec. 1.274-5T(c)(2)(i),
Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
Petitioner provided this Court with no records with respect
to his use of an automobile. Thus, we find that petitioner has
failed to substantiate the deduction claimed for automobile
transportation as required by section 274(d) and the regulations
thereunder. Respondent is sustained on this issue.
Issue 4. Retail Sales Activity Deductions
During the year at issue, petitioner was engaged in selling
magnets that were supposed to promote the relief of pain.
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