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substantiation to support it. Sec. 1.274-5T(a), Temporary Income
Tax Regs., supra.
A. Vehicle-Related Expenses
On Schedule C, petitioner claimed both a section 179 expense
deduction for $7,000 and business-related vehicle expenses of
$4,182 on the same vehicle. It is unclear from the record
whether petitioner used actual expenses or the standard mileage
rate to calculate the claimed deduction of $4,182. No evidence
was introduced to substantiate any actual expenses incurred and
the number of business miles claimed on Schedule C multiplied by
the 1998 standard mileage rate is not equal to the amount of the
claimed deduction.3
Actual expenses related to the business use of a vehicle are
deductible under section 274, if substantiated. If actual
expenses were used to determine the business-related vehicle
expenses claimed, petitioner, having failed to substantiate any
such expense, is not entitled to the business-related vehicle
expenses claimed. See sec. 274(d).
Alternatively, a taxpayer may choose to use the business
standard mileage rate in lieu of the actual automobile expenses.
Nash v. Commissioner, 60 T.C. 503, 520 (1973); Parker v.
Commissioner, T.C. Memo. 1993-15; Rev. Proc. 97-58, 1997-2 C.B.
3 Petitioner reported 12,370 business-related miles and
claimed a deduction of $4,182. The 1998 standard mileage rate of
32.5 cents per mile multiplied by 12,370 miles equals $4,020.25.
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