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or from petitioner’s residence are nondeductible commuting
expenses. The record provides no reliable basis for segregating
petitioner’s nondeductible personal use of his automobile from
any business use (e.g., trips from Romer & Co. to a local airport
or to purchase supplies). For this reason alone, petitioner has
failed to establish entitlement to the claimed mileage
deductions.
Even if we were to assume, arguendo, that whatever miles
petitioner might have driven in the course of normal and
deductible business travel could be, on some rational basis,
segregated from his commuting mileage, petitioner has still
failed to substantiate his expenses adequately. Passenger
automobiles are “listed property” under section 280F(d)(4)(A)(i).
Thus, the mileage expenses are subject to the heightened
substantiation requirements of section 274(d), and no deduction
is allowed with respect to the listed property unless for each
claimed expenditure or use of listed property petitioner
substantiates the requisite elements of amount, time, and
business or investment purpose. See sec. 1.274-5A(c)(2), Income
Tax Regs.; sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50
Fed. Reg. 46016 (Nov. 6, 1985). Petitioner has failed to satisfy
these statutory requirements.
Petitioner claims mileage expense deductions based on his
application of the Federal standard mileage rates to miles he
estimates that he drove in business travel. These mileage
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