- 13 -
Petitioner also deducted on her 1995 and 1996 Schedules C
travel expenses in the amounts of $3,271 and $2,667,
respectively. In the notice of deficiency, respondent
disallowed $2,765 and $2,161 for 1995 and 1996, respectively.
At trial, petitioner introduced no documentary evidence
regarding travel expense.
By virtue of the strict substantiation requirements of
section 274(d), no deduction may be allowed either for travel
or with respect to any “listed property” on the basis of any
approximation or the unsupported testimony of the taxpayer.
See Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per
curiam 412 F.2d 201 (2d Cir. 1969); Golden v. Commissioner,
T.C. Memo. 1993-602; sec. 1.274-5T(a), Temporary Income Tax
Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985); see also sec.
280(F)(d)(4)(A)(i) defining listed property to include a
passenger automobile. Rather, the taxpayer must substantiate
the deduction by adequate records, or by sufficient evidence
corroborating the taxpayer’s own statement, showing: (1) The
amount of each expense or other item; (2) the time and place of
the travel or use of the property; and (3) the business purpose
of the expense or other item. See sec. 274(d). See sec.
1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985), regarding the requisite elements of each
expenditure for travel that must be substantiated; sec. 1.274-
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