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4562, Depreciation and Amortization, as documentary evidence to
substantiate the claimed deduction. Section 1.274-
5T(c)(2)(ii)(C), Temporary Income Tax Regs., 50 Fed. Reg. 46018-
46019 (Nov. 6, 1985), requires that the date of each business use
of an automobile must be stated in order to gain entitlement to a
deduction. While petitioner has identified the business use
mileage, he has failed to describe the automobile used, provide
the dates of use, and identify the business purpose involved.
Petitioner has failed to establish entitlement to this deduction.
Petitioner claimed a deduction of $3,104 for travel expenses
related to flying between Seattle and San Francisco from August
of 1993 throughout the end of that year. As support for these
expenses, petitioner presented copies of travel tickets, various
receipts, and Cilena’s expense account records. In arguing that
the costs were personal in nature, respondent points to the facts
that petitioner stayed with his mother, lived in San Francisco
his whole life prior to moving to Washington, and implied he
visited friends on these trips.
Petitioner argues that the trips were necessary in order to
attend bankruptcy meetings, meet with attorneys, arrange for the
moving and storage of equipment, and recover business records.
No evidence was presented establishing the extent and specific
nature of the business conducted on each trip. The evidence in
the record reflects that petitioner was no longer the owner of
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