- 17 - relating to certain forms of “listed property.” For these items, taxpayers must show that an expense was “directly related” to business activity, and must provide the business purpose, amount, and time and place of the expenditure. Sec. 1.274-5T(b)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). We consider petitioner’s claimed deductions in this context. 1. Mileage Section 280F(d)(4)(A)(i) makes a personal automobile “listed property”, and thus subject to enhanced substantiation requirements. Section 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985) describes those requirements, and provides that “[w]ritten evidence has considerably more probative value than oral evidence alone. In addition, the probative value of written evidence is greater the closer in time it relates to the expenditure or use.” Sec. 1.274- 5T(c)(1). Section 1.274-5T(c)(2)(ii)(C)(2), Temporary Income Tax Regs., 69 Fed. Reg. 32782 (June 10, 2004), specifically identifies “a record of the business use of listed property, such as a computer or automobile, prepared in a computer memory device with the aid of a logging program” as an adequate written record. Petitioner has provided just such a record. Section 1.274-5T(b)(2), Temporary Income Tax Regs., lists the information a taxpayer’s records must contain to substantiate travel away from home. These are: (1) the amount of the expenditure; (2) the date of each departure and return and numberPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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