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a vehicle expense deduction of $4,182. At trial, petitioner
presented no evidence to substantiate the business mileage
reported or the vehicle expense claimed. Petitioner testified
that he did not “keep” his business mileage. Petitioner’s
witness, Alonza O. C. Sargent, testified that petitioner did
maintain a mileage log, but no such log was introduced at trial.
As stated above, section 274 requires strict substantiation
for deductions claimed for transportation in a passenger car.
Petitioner is required to provide a mileage log or other
corroborative evidence sufficient to establish the amount, time,
place, and business purpose of the expense. Sec. 274(d). At
trial, petitioner failed to provide any corroborating evidence
whatsoever to satisfy the section 274 substantiation
requirements.
Based on a partial mileage log reviewed by respondent during
an examination prior to trial, respondent conceded that
petitioner was entitled to 5,742 business miles.4 Applying the
standard mileage rate for 1998, respondent concedes that
petitioner is entitled to a vehicle expense deduction of $1,866
for the year at issue. Although petitioner did not substantiate
entitlement to a deduction in any amount at trial, we shall not
disturb the respondent’s concession. Accordingly, petitioner is
4 The partial mileage log was not introduced at trial.
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