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Commissioner, 30 T.C. 757, 767-769 (1958); Udoh v. Commissioner,
T.C. Memo. 1999-174; Beckey v. Commissioner, T.C. Memo. 1994-514.
Petitioner’s testimony indicates that the articles of clothing
claimed as expenses were adaptable to general use. Therefore,
petitioner’s clothing expenses are personal expenses and are not
deductible.
Petitioner testified that he was entitled to larger
deductions for vehicle expenses related to business mileage than
allowed by respondent. Petitioners, however, presented no
evidence other than a summary of the expenses claimed on their
Schedules A and C. Under section 274(d), the elements that must
be substantiated to deduct business use of an automobile are:
(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. See sec. 1.274-5T(b)(6), Temporary Income Tax Regs.,
50 Fed. Reg. 46014 (Nov. 6, 1985). Petitioners failed to
substantiate any of these elements at trial.
Although petitioners did not claim deductions for child care
on their 1996 return or assert their entitlement to such
deductions in their petition, petitioner raised this issue at
trial. Generally, we do not consider issues raised for the first
time at trial. See Vetco Inc. v. Commissioner, 95 T.C. 579, 589
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