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taxpayer uses a vehicle for both business and personal purposes,
and he uses the vehicle for deliveries on a regular, established
route, then he may satisfy the adequate record requirement by
recording the total number of miles driven during the tax year,
the length of the route, and the date of each trip. The date of
each trip should be recorded at or near the time of each trip.
In addition, the taxpayer could establish the date of each trip
with a receipt, record of delivery, or other documentary
evidence. See sec. 1.274-5T(c)(2)(ii)(C)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46018 (Nov. 6, 1985). If a taxpayer
cannot meet the requirements of section 274(d), then he is not
entitled to a deduction.
A. Automobile Expenses
Petitioner deducted the following amounts related to his
1995 Dodge van and 1997 Ford Mustang: $2,480 and $2,559 in 1996
and 1997, respectively, for car and truck expenses (mileage);
interest of $2,479 and $1,215 in 1996 and 1997, respectively; and
$2,152 for taxes and licenses in 1997. Petitioner testified that
he used the van exclusively for the delivery of baked goods to
IBC’s customers on his days off and after hours. Petitioner did
not testify as to the business use of the Mustang. Petitioner
stated that when he purchased the Mustang, he stopped using the
van, as he did not need to deliver as much bread. Petitioner
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