Fatai O. and Mary King - Page 9




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               The "adequate records" standard requires that a taxpayer               
          maintain an account book, diary, log, statement of expense, trip            
          sheet, or other similar record that contains entries of                     
          expenditures made at or near the time of the expenditure.  In               
          addition, a taxpayer must supply documentary evidence, such as              
          receipts, paid bills, or similar evidence sufficient to support             
          an expenditure.  See sec. 1.274-5T(c)(2)(i), (iii), Temporary               
          Income Tax Regs., 50 Fed. Reg. 46017, 46019 (Nov. 6, 1985).                 
          Alternatively, taxpayers who are unable to satisfy the adequate             
          records requirement are still entitled to a deduction for                   
          expenses that they can substantiate with other corroborative                
          evidence.  See sec. 1.274-5T(c)(3), Temporary Income Tax Regs.,             
          50 Fed. Reg. 46020 (Nov. 6, 1985).                                          
               The only evidence offered to substantiate these expenses was           
          receipts for automobile repair bills totaling $2,708.48, a copy             
          of a $500 check dated January 8, 1995, with a notation on the               
          check indicating that it was used for car insurance on a "1986              
          Mercury Topez [sic]", and Mr. King's self-serving testimony.                
          Since Mr. King testified that the expenses he seeks to deduct               
          relate to the Hyundai, the check relating to the Mercury Topaz is           
          irrelevant.                                                                 










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