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includes a written statement of business purpose (unless such
business purpose is evident from the surrounding facts and
circumstances) and sufficient information as to each element of
every business use. Sec. 1.274-5T(c)(2)(i) and (ii), Temporary
Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
As pertinent here, section 1.274-5T(c)(3)(ii), Temporary
Income Tax Regs., 50 Fed. Reg. 46021 (Nov. 6, 1985), entitled
“Sampling”, provides a method of substantiation that a taxpayer
may use if the taxpayer does not maintain an adequate record
within the meaning of section 274(d) and the regulations thereun-
der for the entire taxable year. That section provides that
generally a taxpayer may meet the sufficient evidence requirement
under section 274(d) and the regulations thereunder by maintain-
ing an adequate record for a portion or portions of a taxable
year and using that record to substantiate the business use of
listed property for all of that year. However, the taxpayer must
demonstrate by other evidence that the use for the portion or
portions of the taxable year for which the adequate record is
maintained is representative of the use for the taxable year
(sampling method of substantiation). Sec. 1.274-5T(c)(3)(ii)(A),
Temporary Income Tax Regs., 50 Fed. Reg. 46021 (Nov. 6, 1985).
The sampling method of substantiation may not be used to substan-
tiate the business use of an employer-provided automobile that is
made available for use by more than one employee for all or a
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