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After estimating petitioner’s fuel expense, respondent conceded
that petitioner is entitled to a deduction for car and truck
expenses in the amount of $134.40.
Although we have no doubt that petitioner had more
automobile expenses than those listed above and probably drove
more business miles than respondent conceded, we agree
petitioner’s failure to substantiate his automobile expenses
forecloses any greater deduction. Section 274(d)(4) provides, in
pertinent part, that no deduction or credit shall be allowed
under section 162 with respect to any listed property (as defined
in section 280F(d)(4)) unless the taxpayer substantiates by
adequate records or by sufficient evidence corroborating the
taxpayer’s own statement: (a) The amount of such expense or
other item, (b) the time and place of the use of the property,
and (c) the business purpose of the expense or other item.
Section 1.274-5T(b)(6), Temporary Income Tax Regs., provides
a more detailed statement confirming that a taxpayer must prove
the following with respect to listed property: (a) The amount of
each separate expenditure with respect to an item of listed
property, such as the cost of lease payments, the cost of
maintenance and repairs, or other expenditures, (b) the amount of
each business use based on the appropriate measure (i.e., mileage
for automobiles) and the total use of the listed property for the
taxable period, (c) the date of the expenditure or use with
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