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automobile, the taxpayer must comply with strict substantiation
requirements under section 274(d)(4). Section 274 requires, in
relevant part, that the taxpayer substantiate by either adequate
records or sufficient corroborating evidence the following items:
(1) The amount of the claimed expense; (2) the time and place of
the use of the property; and (3) the business purpose of the
expense. Sec. 274(d); sec. 1.274-5T(b)(6), Temporary Income Tax
Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). Even if such an
expense is otherwise deductible, the deduction for the listed
item may be denied if the substantiation is insufficient to
support it. Id. The substantiation requirements under section
274 override the general substantiation requirements of section
6001 and Cohan v. Commissioner, supra.
A self-employed individual may deduct a mileage allowance
under section 62(a)(1), section 1.274-5T(c)(2)(ii), Temporary
Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985), and section
1.274(d)-1, Income Tax Regs. Dehr v. Commissioner, T.C. Memo.
1998-441. A deduction for a mileage allowance requires the same
substantiation under section 274 as set forth above (i.e.,
amount, time and place, and business purpose). The amount of the
mileage can be substantiated by any reasonable means, such as
using a contemporaneous business log, or otherwise establishing
the miles driven. Smith v. Commissioner, 80 T.C. 1165 (1983).
The Commissioner is authorized to establish the standard mileage
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