- 31 - 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 isPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
Last modified: May 25, 2011