- 81 - Assuming arguendo that petitioners had established that they used petitioners’ two automobiles in a trade or business or that they held such automobiles for the production of income, peti- tioners must satisfy the substantiation requirements of section 274(d)(4) and the regulations thereunder. Petitioners concede that they kept no records with respect to the business use of petitioners’ two automobiles. Consequently, petitioners may establish their entitlement to the depreciation deductions at issue only by introducing into the record in this case their own statements and sufficient evidence corroborating such statements. See sec. 274(d)(4); sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Petitioners introduced no evidence at trial that supports their position with respect to the depreciation deductions at issue. On the instant record, we find that petitioners have failed to establish that they satisfy the substantiation requirements of section 274(d)(4) and the regulations thereunder regarding those deductions. Based on our examination of the entire record before us, we find that petitioners have failed to establish their entitlement to the depreciation deductions at issue. Consequently, we sustain respondent’s determination with respect to those claimed deductions. Respondent’s Determination Regarding the Accuracy-Related Penalty Under Section 6662(a) In the notice, respondent determined that petitioners arePage: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
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