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respect to listed property, and (d) the business purpose for an
expenditure or use.
Petitioner simply did not comply with section 274(d).
Petitioner did not maintain a contemporaneous diary, calendar, or
mileage log of his business travel, and he has failed to prove
that he otherwise made a record of the alleged business use of
his automobile at or near the time of the use. He did not retain
receipts for most of the expenses he claimed to have paid, and he
did not establish the total business miles driven during 1994.
Even after we gave petitioner the opportunity to produce
additional records to respondent and the Court following trial,
petitioner failed to take the necessary steps to supplement the
record in this case.
On this record, we sustain respondent’s adjustment to
petitioner’s car and truck expense deduction as modified.
Depreciation and Section 179 Expenses
On his 1994 Schedule C, petitioner claimed total deductions
for depreciation and section 179 expense of $10,260. On Form
4562, Depreciation and Amortization, Part I, Election to Expense
Certain Tangible Property (Section 179), petitioner described the
property as “computer, fax, printer, furniture, desks, chairs,
lamps” and claimed a cost of $10,260. Petitioner now contends
that he is entitled to a greater section 179 deduction, as
reflected on an exhibit entitled “Summary of 1994 179 Expenses”.
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