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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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