- 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