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also find that they are entitled to deduct $852 as expenses for
supplies.
The amount of $12,105 claimed as “commissions” paid to Brett
for his work in the locksmith business is allowed only to the
extent of $3,600, the amount recorded in the check register. No
other evidence was provided by petitioners.
2. Claimed Car and Truck Expenses
Section 274(d) imposes stringent substantiation requirements
for the deduction of travel expenses and expenses of certain
listed property defined under section 280F(d)(4), such as an
automobile. For such expenses 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). If an expense item comes within the requirements of
section 274(d), this Court cannot rely on Cohan v. Commissioner,
supra, to estimate the taxpayer’s expenses with respect to that
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