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similar record, and documentary evidence that, in combination,
are sufficient to establish each element of each expenditure or
use. Sec. 1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed.
Reg. 46017 (Nov. 6, 1985). To be adequate, a record must
generally be written. Each element of an expenditure or use that
must be substantiated should be recorded at or near the time of
that expenditure or use. Sec. 1.274-5T(c)(2)(ii)(A), Temporary
Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Thus, under
section 274(d) no deduction may be allowed for expenses incurred
for use of a passenger automobile on the basis of any
approximation or the unsupported testimony of the taxpayer.
Bradley v. Commissioner, T.C. Memo. 1996-461; Golden v.
Commissioner, T.C. Memo. 1993-602.
Personal expenses are not deductible, unless expressly
provided for in chapter 1 of the Internal Revenue Code. Sec.
262. Section 162(a) expressly permits a deduction for "traveling
expenses * * * while away from home in the pursuit of a trade or
business". An individual's tax home under this provision
generally is the individual's principal place of business, not
the location of his personal residence. Mitchell v.
Commissioner, 74 T.C. 578, 581 (1980). An exception exists under
which an individual's tax home is his personal residence if his
principal place of business is temporary rather than indefinite.
Peurifoy v. Commissioner, 358 U.S. 59, 60 (1958). The flush
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