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In sum, petitioner is not entitled to deductions for meals
and incidental expenses relating to his Nashville residency or
employment.
(iv) Nashville Automobile Expenses
Petitioner alleges that he purchased two “junk airport cars”
for his transportation in Nashville and that he used them solely
because he was conducting business in Nashville. He seeks to
deduct $1,057 relating to the purchase and repair of these cars.
Petitioner has failed to prove that the automobiles he
purchased in Nashville were used solely for business purposes.
It stands to reason that they were not, given that petitioner’s
personal residence was in Nashville. Even if we were to assume,
arguendo, that the automobiles were used for business purposes,
petitioner’s claim for deductions still must fail. Section 263
denies a deduction for the cost of acquisition of machinery and
equipment and similar property having a substantial life beyond
the taxable year. See sec. 1.263(a)-1(b) and (a)-2(a), Income
Tax Regs. Moreover, automobiles are “listed property” under
section 280F(d)(4), thereby requiring petitioner to meet the
heightened substantiation requirements of section 274(d).
Petitioner has failed to establish with any particularity the
time and place of the use of the cars or the business purpose of
each use. Petitioner thus fails to meet the substantiation
requirements of section 274.
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