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requirements. These include adequate records or other
corroborating evidence of the amount of the expense, the time and
place of the automobile’s use, and the business purpose of its
use. See Sanford v. Commissioner, 50 T.C. 823, 827-828 (1968),
affd. 412 F.2d 201 (2d Cir. 1969); Maher v. Commissioner, T.C.
Memo. 2003-85. Petitioner claims he is entitled to deduct $8,910
in business expenses related to mileage traveled for work.
Petitioner testified that he recorded annual mileage on December
31 of each year which tended to average approximately 36,000
miles and used that odometer reading as his mileage log to then
take 90 percent as a deduction for work-related travel.
Petitioner, however, submitted no documentation or receipts to
substantiate any of the business expenses he claims he incurred
in 1996. Accordingly, we conclude petitioner is not entitled to
deduct mileage as an automobile expense.
2. Home Office Expenses
Section 280A(a) generally provides that no deduction
otherwise allowable shall be allowed with respect to the business
use of a taxpayer’s residence. Section 280A(c) provides
exceptions to the general rule of section 280A(a) and requires
that expenses be allocated between the business and personal use
of the dwelling. Thus, as relevant herein, section 280A(a) does
not apply to any item to the extent that the item is allocable to
a portion of the dwelling unit that is exclusively used on a
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