- 7 -7 (1986). We find that petitioner’s principal place of business was the Plymouth office. Accordingly, petitioner’s expenses of driving to and from Plymouth are nondeductible commuting expenses. Commissioner v. Flowers, 326 U.S. 465, 473-474 (1946). Because the record is not clear as to the exact amounts of disallowance of car and truck expense deductions, we consider section 274(d). Section 274(d)(4) imposes stringent substantiation requirements for the deduction of certain listed property as defined under section 280F(d)(4), such as an automobile. Taxpayers must substantiate by adequate records the following items in order to claim automobile deductions: The amount of each separate expenditure, the listed property’s business and total usage, the date of the expenditure or use, and the business purpose for an expenditure or use. Sec. 274(d); sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). To substantiate a deduction by means of adequate records, a taxpayer must maintain an account book, diary, log, statement of expense, trip sheets, and/or other documentary evidence which, in combination, are sufficient to establish each element of expenditure or use. Sec. 1.274- 5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Petitioner had no such records. Petitioner did not attempt to satisfy the requirements of section 274(d). Because ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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