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all of petitioner’s work sites were south of Sacramento.
Accordingly, we uphold respondent’s determination that
petitioner is not entitled to deduct automobile expenses for
transportation to her temporary jobsites.
Schedule C Automobile Expenses
Respondent contends petitioner is not entitled to a
deduction for $809 of the $1,801 in car and truck expenses she
claimed on her 1995 Schedule C because she has not substantiated
the mileage she drove for her Amway activities, nor has she
presented evidence of the total miles she drove during 1995.
Petitioner maintains that she has substantiated mileage from her
Amway activity, and thus is entitled to a deduction for the full
$1,801 she claimed on her return.
Section 274(d) imposes stringent substantiation requirements
for claimed deductions relating to the use of “listed property”,
which is defined under section 280F(d)(4)(A)(i) to include
passenger automobiles. Under this provision, any deduction
claimed with respect to the use of a passenger automobile will be
disallowed unless the taxpayer substantiates specified elements
of the use by adequate records or by sufficient evidence
corroborating the taxpayer’s own statement. See sec. 274(d);
sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
46018 (Nov. 6, 1985). These substantiation requirements
supersede the doctrine found in Cohan v. Commissioner, 39 F.2d
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