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computers and peripheral equipment. Sec. 280F(d)(4). To meet
the strict substantiation requirements, the taxpayer must
substantiate the amount, time, place, and business purpose of the
expenses. Sec. 274(d); sec. 1.274-5T, Temporary Income Tax
Regs., 50 Fed. Reg. 46006 (Nov. 6, 1985).
In order to substantiate the amount of expenses for listed
property, a taxpayer must establish the amount of business use
and the amount of total use for such property. Sec. 1.274-
5T(b)(6)(i)(B), Temporary Income Tax Regs., 50 Fed. Reg. 46006
(Nov. 6, 1985). With respect to the use of automobiles, in order
to establish the amount of an expense the taxpayer must establish
the amount of business mileage and the amount of total mileage
for which the automobile was used. Sec. 1.274-5T(b)(6)(i)(B),
Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
The taxpayer may substantiate the amount of mileage by adequate
records or by sufficient evidence corroborating his own
statement. Sec. 274(d). A record of the mileage made at or near
the time the automobile was used, supported by documentary
evidence, has a high degree of credibility not present with a
subsequently prepared statement. Sec. 1.274-5T(c)(1), (2), and
(3), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,
1985).
We do not accept Mr. Brayshaw’s testimony that the Jeep was
used exclusively for business purposes. We find it highly
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