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Sec. l.274-5T(c)(l), Temporary Income Tax Regs., 50 Fed. Reg.
46016 (Nov. 6, 1985).
The only documentation presented by petitioner at trial with
respect to his claimed expenses was a document he prepared, which
purported to establish the mileage of his vehicle in connection
with his employment but only for 9 months of 1999. He had no
documentary information for 2000. He presented no hotel or
restaurant receipts, nor did the documentary information include
information as to the time, place, and business purpose for each
occasion or instance in which the vehicle was used in connection
with his employment. Petitioner also submitted receipts from
various service stations that reflected various mechanical
services to the vehicle; however, nothing on those documents has
any relevance to the issue before the Court. The documentation
does not satisfy the substantiation requirements of section
274(d), and, to the extent petitioner's claimed expenses relate
to travel expenses away from home, respondent is sustained.
The Court recognizes that petitioner also used his vehicle
in connection with his employment, which did not involve his
being away from home within the intent and meaning of section
162(a)(2). Such expenses are subject to the same substantiation
requirements. Section 274(d) includes transportation expenses
incurred in the use of "listed property" as defined in section
280F(d)(4). Under that section, "listed property" includes,
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