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The third deduction concerns claimed car and truck expenses
of $3,120.7 The substantiation requirements under section 274
apply to passenger automobiles. See secs. 274(d)(4),
280F(d)(4)(A)(i).8 Normally, deductions for automobile expenses
are not allowed unless the taxpayer substantiates the deduction
through either adequate records or the taxpayer's own detailed
statement that is corroborated by sufficient evidence. See sec.
274(d)(4). At a minimum, the taxpayer must substantiate: (1)
The amount of the expense, (2) the time and place the expense was
incurred, and (3) the business purpose for an expenditure or use
with respect to listed property. See sec. 274(d); sec. 1.274-
5T(b)(6)(i), (iii), Temporary Income Tax Regs., 50 Fed. Reg.
46016 (Nov. 6, 1985).
7Petitioners claimed expenses of $3,120 for car and truck,
$1,025 for insurance, and $2,935 for legal and professional
services in their amended return but nothing for the same items
in their original return. On the other hand, petitioners claimed
$250 for advertising expenses, $500 for office expenses, and
$17,500 for supplies in their original income tax return, while
claiming no deduction for advertising or office expenses and only
$171 for supplies in their amended return. See appendix.
8Sec. 274(d)(4) provides, in part, that "No deduction or
credit shall be allowed * * * with respect to any listed property
(as defined in section 280F(d)(4))".
Sec. 280F(d)(4)(A)(i) provides that the "term 'listed
property' means * * * any passenger automobile".
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