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than money. Moreover, the Court is satisfied from the record
that the amounts deducted as charitable contributions on
petitioners' returns were arbitrarily determined by the return
preparer. On this record, the Court sustains respondent on the
disallowed charitable contribution deductions for 1999 and 2000.
The claimed deductions for unreimbursed employee business
expenses related to the use of petitioner's personal vehicle in
connection with his employment. Petitioner never sought
reimbursement for such expenses from his employer. He did not
maintain a log or other contemporaneous record documenting the
use of his vehicle.4 The amounts claimed as deductions on the
returns were also arbitrarily determined by the return preparer.
The deductions cannot be allowed for the reason that, under
section 274(d) and the regulations thereunder, vehicle expenses
are subject to strict substantiation rules that require "adequate
records" through either an account book, diary, statement of
expense, or similar record, as well as documentary evidence to
establish each element of an expenditure. Sec. 1.274-
5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov.
6, 1985). No records were presented at trial to substantiate
these expenses; consequently, respondent is sustained on the
4 The Court notes that the $14,217 of unreimbursed
employee expenses represented 45.5 percent of petitioner's wages
for 1999. The same category of expenses for 2000 represented
21.3 percent of his wages.
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