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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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