Nicholas M. Romer - Page 31




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          estimates, in turn, he claims to base on flight logbooks, some              
          retail store receipts, and a map of the Minneapolis area.                   
          Petitioner failed to keep a mileage log and failed to document in           
          any way the business use of his vehicles.  Use of the Federal               
          standard mileage rates serves only to substantiate the amount of            
          expenses.  See Rev. Proc. 89-66, 1989-2 C.B. 792, updated and               
          amplified by Rev. Proc. 90-59, 1990-2 C.B. 644.  Petitioner’s               
          records do not substantiate the remaining elements of time and              
          business purpose.  Petitioner’s unsupported, self-serving                   
          testimony did not adequately substantiate any of the necessary              
          elements under section 274(d).  Therefore, petitioner is not                
          entitled to deductions for his alleged automobile expenses.                 
               13.  Travel Expenses                                                   
               Petitioner contends that for each of the years at issue he             
          is entitled to deduct unagreed travel expenses, which fall into             
          two general categories:  (a) Travel expenses relating to                    
          petitioner’s Minneapolis-based aviation activities, and (b)                 
          travel expenses relating to petitioner’s Nashville-based                    
          employment with Flagship Airlines.                                          
               Under section 262, personal living expenses are generally              
          nondeductible.  A taxpayer may deduct travel expenses, including            
          amounts for meals and lodging, incurred “while away from home in            
          the pursuit of a trade or business”.  Sec. 162(a)(2); see                   
          Commissioner v. Flowers, supra at 470.  For purposes of section             
          162(a)(2), a taxpayer is not “away from home” unless he or she is           





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