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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 number
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