Steven L. and Laura J. Chambers - Page 10




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          the salaries and wages petitioners earned each year.  The amounts           
          claimed allegedly represented the costs petitioners incurred in             
          using their personal vehicles in connection with their                      
          employment.  Some of the expenses also were for what petitioners            
          identified as "Work/Tool Expenses".                                         
               Petitioners did not maintain any log or other record                   
          documenting the dates, times, and places their vehicles were used           
          in connection with their respective employments during the years            
          in question.                                                                
               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                
          disallowance of the employee business expense deductions.7                  



               7    The Forms W-2, Wage and Tax Statement, that were                  
          offered in evidence with petitioners' tax returns indicate that             
          petitioner Steven L. Chambers was an employee of the United                 
          States Government.  The Court is very skeptical that a Federal              
          employee incurring job-related expenses of the magnitude claimed            
          on petitioners' returns would not have been reimbursed in whole             
          or in part by the employing Federal agency.                                 




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