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540 (2d Cir. 1930), under which we may approximate expenses in
certain cases where the exact amount of expense cannot be
determined. See sec. 1.274-5T(a), Temporary Income Tax Regs., 50
Fed. Reg. 46015 (Nov. 6, 1985).
The elements that must be substantiated to deduct business
use of an automobile are: (1) The amount of the expenditure; (2)
the mileage for each business use of the automobile and the total
mileage for all use of the automobile during the taxable period;
(3) the date of the business use; and (4) the business purpose of
the use of the automobile. See sec. 1.274-5T(b)(6), Temporary
Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
To meet the adequate records requirements of section 274(d),
a taxpayer must maintain some form of records and documentary
evidence that in combination are sufficient to establish each
element of an expenditure or use. See sec. 1.274-5T(c)(2),
Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). A
contemporaneous log is not required, but corroborative evidence
to support a taxpayer's reconstruction of the elements of
expenditure or use must have "a high degree of probative value to
elevate such statement" to the level of credibility of a
contemporaneous record. Sec. 1.274-5T(c)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
Petitioner testified that she carried a calendar with her in
her car and filled it out each day, recording any Amway business
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