- 13 - 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 vehiclePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011