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automobile. Sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50
Fed. Reg. 46016 (Nov. 6, 1985).
To meet the adequate records requirements of section 274(d),
a taxpayer must maintain some form of records and documentary
evidence that in combination are sufficient to establish each
element of an expenditure or use. Sec. 1.274-5T(c)(2), Temporary
Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). A
contemporaneous log is not required, but corroborative evidence
to support a taxpayer’s reconstruction of the elements of
expenditure or use must have “a high degree of probative value to
elevate such statement and evidence” to the level of credibility
of a contemporaneous record. Sec. 1.274-5T(c)(1), Temporary
Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
On her 1997 Federal income tax return, petitioner claimed
that during 1997 her vehicle was driven 62,730 miles, of which
59,610 were business miles. On her Schedule A, petitioner
reported business mileage of 54,570 miles, and on her Schedule C,
she reported business mileage of 5,040 miles. Her vehicle
expenses were computed using the appropriate standard mileage
rate for 1997 of 31.5 cents. See Rev. Proc. 96-63, 1996-2 C.B.
420, 422.
During 1997 petitioner maintained a log of the odometer
readings for her vehicle. The log contains the names of the
cities to which petitioner drove. The log shows that the vehicle
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