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may exclude all or part of the prorated annual lease value of the
automobile as a working condition fringe under section 132. Sec.
1.132-5(c)(2), Income Tax Regs.
Section 274(d)(4) requires a taxpayer to substantiate, by
adequate records or by sufficient evidence corroborating the
taxpayer’s own statement, the following four elements before a
deduction or credit with respect to the alleged business use of
an automobile will be allowed: (1) The amount of the
expenditure; (2) the mileage for each business use of the
automobile and the total mileage for all use of the automobile
during the taxable period; (3) the date of the business use; and
(4) the business purpose of the use of the automobile. Sec.
1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016
(Nov. 6, 1985).
Although the applicable regulations provide considerable
guidance to employees who, like Deborah, seek to exclude a
portion of the value of a company-supplied automobile from their
income as a working condition fringe and are required to
substantiate their business use of the automobile, e.g., sec.
1.132-5(c) through (f), Income Tax Regs.; sec. 1.274-5T(b)(6) and
(c), (e), Temporary Income Tax Regs., 50 Fed Reg. 46016 (Nov. 6,
1985); sec. 1.274-6T, Temporary Income Tax Regs., 50 Fed. Reg.
46037 (Nov. 6, 1985), Deborah’s effort to substantiate business
use consisted solely of general testimony that she used the
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