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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).
Petitioner provided a calendar with circled numbers that
allegedly represent the total number of miles driven each day for
business purposes. Petitioner also had a hand-written sheet with
the total business and nonbusiness miles traveled during the year
in his car and truck. There was no mention in any document of
where petitioner traveled, who he visited, or the business
purpose of each trip. Many notations appear to be personal in
nature. Even assuming petitioner had a trade or business, these
records are not adequate to satisfy the requirements of section
274. We sustain respondent's determination as to this issue.
Petitioners reported a $12,000 annual installment payment
from the sale of their home and farm as income on their Schedule
F, Profit or Loss From Farming, under "Sales of livestock,
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