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274(d), a taxpayer "shall maintain an account book, diary, log,
statement of expense, trip sheets, or similar record * * * and
documentary evidence * * * which, in combination, are sufficient
to establish each element of an expenditure". Sec. l.274-
5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov.
6, 1985). (Emphasis added.) The elements to be proven with
respect to each traveling expense are the amount, time, place,
and business purpose of the travel. Sec. l.274-5T(b)(2),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
The substantiation requirements of section 274(d) are designed to
encourage taxpayers to maintain records, together with
documentary evidence substantiating each element of the expense
sought to be deducted. Sec. l.274-5T(c)(l), Temporary Income Tax
Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). Petitioners presented
no records or other documentary information that would satisfy
the requirements of section 274(d) and the regulations cited.
Moreover, to the extent petitioner used his vehicle locally and
not for travel away from home within the intent and meaning of
section 162(a)(2), such expenses are also subject to the same
substantiation requirements because section 274(d) includes
transportation expenses incurred in the use of "listed property"
as defined in section 280F(d)(4). A passenger automobile is
listed property. Sec. 280F(d)(4)(A)(i) and (ii). Similarly, any
computer or peripheral equipment not used at a regular business
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