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deduct an amount on Schedule A for meals, nor has he
substantiated an amount therefor. Because the Cohan doctrine is
superseded by section 274, which requires strict substantiation
for meals, petitioner is not entitled to a Schedule C deduction
for the $306 of meals.
Petitioner alleges that $290 of mileage expense was incurred
during the L.A. Models Inc. job. Respondent agreed that
petitioner did substantiate the total mileage deduction on
Schedule A. However, no evidence was presented relating to
actual operating and fixed costs for this travel. Petitioner
testified that he traveled 120 miles round trip for 4 days
working on the job, for a total of 480 miles. Since the business
standard mileage rate for 1997 was 31.5 cents per mile,
petitioner is entitled to a Schedule C deduction of $176 for
mileage expense. See Rev. Proc. 96-63, 1996-2 C.B. 420.
Petitioner asserts that $750 of expense relating to a
computer should be deducted on Schedule C. Pursuant to section
280F(d)(4), a computer is listed property. As such, a deduction
relating to a computer requires strict substantiation under
section 274(d). Petitioner failed to present any evidence that
the computer was used to obtain the L.A. Models Inc. job.
Further, petitioner failed to present the amount of personal
computer use to determine the business use percentage.
Petitioner’s failure to substantiate sufficiently the computer
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