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Under section 280F(d)(4), petitioners’ truck is listed
property and is subject to the stringent substantiation
requirements of section 274(d). See sec. 280F(d)(4)(A)(i), (ii),
(5)(A). Petitioners must substantiate by adequate records the
four requirements of section 274(d). See sec. 274(d); sec.
1.274-5T(b)(6), (c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
46016 (Nov. 6, 1985).
While petitioners did retain receipts which indicate the
amount of each expenditure, petitioners have failed to show the
business and total usage of the truck. Petitioners did not
establish how they came up with the 80-percent figure, nor did
they maintain any logs or records on the use of their truck.
Based on this lack of evidence, we cannot find that petitioners
are entitled to a deduction for vehicle expenses. Therefore,
respondent is sustained on this issue.
Office/Household Expenses
Petitioners claimed a deduction of $5,132 for “allowable
office/household expenses”. This amount reflects 33 1/3 percent
of petitioners’ household expenses. The household expenses
consist of insurance, mortgage interest, utilities, cable
television, pool service, yard service, home improvements, and
numerous expenses at retail stores.
Section 262 disallows any deduction for personal, living, or
family expenses, and included in this category is the expense of
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