- 19 -
include passenger automobiles and other property used as a means
of transportation. See sec. 280F(d)(4)(A)(i) and (ii).
Petitioners acknowledge that they kept no records of the
type required by section 274(d) and the regulations thereunder.
Consequently, petitioners may establish their entitlement to the
Schedule C car and truck expenses that respondent disallowed for
each of the years at issue only by introducing into the record in
this case their own statements and sufficient evidence corrobo-
rating such statements. See sec. 274(d)(4); sec. 1.274-5T(c)(1),
Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
We find that the general, vague, and conclusory testimony of
petitioners regarding the number of miles that one or more of
their vehicles was driven for business purposes during each of
the years at issue does not satisfy those substantiation require-
ments.
Based upon our examination of the entire record before us,
we find that petitioners have failed to establish that they are
10(...continued)
* * * * * * *
(4) with respect to any listed property (as de-
fined in section. 280F(d)(4)),
unless the taxpayer substantiates by adequate records
or by sufficient evidence corroborating the taxpayer’s
own statement (A) the amount of such expense or other
item, (B) the time and place of the * * * use of the
facility or property * * * , (C) the business purpose
of the expense or other item * * * .
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011