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business miles for a business-related vehicle expense deduction
of $6,274.3 Thus, petitioner must substantiate the difference of
$567 to claim it as a deduction. See sec. 274(d).
At trial, petitioner presented absolutely no evidence to
substantiate the business mileage reported. Petitioner testified
that he did not have a mileage log.
As stated above, section 274(d) requires strict
substantiation for deductions claimed for transportation in a
passenger car. Petitioner is required to provide adequate
records 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(d)
substantiation requirements.
Accordingly, petitioner is not entitled to a business
expense deduction on the barber shop Schedule C greater than the
$6,274 respondent allowed. Respondent is sustained on this
issue.
3 The deduction was determined using the 1997 standard
mileage rate of 31.5 cents per mile.
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Last modified: May 25, 2011