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for showers, $30 for truck parking, $30 for laundry, and $32 for
Federal Express charges. These expenses averaged $5.60 per day,
using a 28-day month. David Butler estimated monthly expenses as
follows: $117 for motels, $50 for showers, $20 for truck
parking, $22 for laundry, and $32 for Federal Express charges.
These expenses averaged $8.60 per day, using a 28-day month.
William Lane estimated monthly expenses as follows: $65 for
motels, $60 for showers, $55 for truck parking, $30 for laundry,
and $32 for Federal Express charges. These expenses averaged
$8.64 per day, using a 28-day month. Mr. Lane estimated his
expenses for meals at approximately $24-25 per day.
Despite the credible testimony of the witnesses, we find
that petitioners did not substantiate the travel expense
deductions of their approximately 300 drivers pursuant to strict
standards of section 274(d) and the regulations. Petitioners did
not establish the amount, time, or place of each separate
expenditure for each of the drivers. Sec. 1.274-5T(b)(2)(i),
Temporary Income Tax Regs. Petitioners did not establish the
dates of departure and return for each trip away from home by
each driver, or the exact number of days away from home. Sec.
1.274-5T(b)(2)(ii), Temporary Income Tax Regs. Petitioners did
not establish the exact destination or locality of travel, as
described by name of city or town or other similar designation.
Sec. 1.274-5T(b)(2)(iii), Temporary Income Tax Regs.
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