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Taxpayers must substantiate by adequate records certain items in
order to claim deductions, such as the amount and place of each
separate expenditure, the 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), Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (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). Travel, and car and
truck expenses cannot be estimated under Cohan. Sanford v.
Commissioner, 50 T.C. 823, 827-828 (1968), affd. per curiam 412
F.2d 201 (2d Cir. 1969).
Petitioner did not have any books or records. He did not
have a diary, log, or trip sheets relating to his travel.
Petitioner did not satisfy the strict requirements of section 274
with respect to his travel. At trial, petitioner had little
evidence to support many of his claimed deductions. He provided
some substantiation of medical and other expenses.
In addition, there is no credible evidence in the record
which supports the contention that petitioner performed services
for persons other than his three employers. The only indication
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