Gary G. Bendickson - Page 8




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          (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 of                  





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