- 6 -
Petitioner does not have a mileage log or any other
documentation to substantiate his claim. Petitioner contends
that he kept a cash account book on his person at all times in
which he recorded “everything”. This account book was destroyed
by the flooding in the apartment. No miles or trips were
recorded on the calendar submitted at trial.
Passenger automobiles are listed property under section
280F(d)(4)(A)(i), and they are subject to the strict
substantiation requirements of section 274(d). Petitioner did
not reconstruct any records with regard to the mileage he
incurred.
On the basis of this record, we are precluded from allowing
a deduction for any vehicle expenses. We sustain respondent with
respect to this item.
2. Parking
Petitioner claimed a deduction of $780 for parking expenses.
The dealership does not provide parking for the employees.
Therefore, petitioner parked at a nearby parking lot for which he
paid parking fees of $780 for the year. It is well settled that
parking fees a taxpayer incurs as a part of his or her daily
commute are nondeductible personal expenses. See sec. 262; see
also Commissioner v. Flowers, 326 U.S. 465, 470 (1946).
Accordingly, respondent is sustained on this item.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011