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regulations which except taxpayers from strict substantiations in
the case of expenditures of less than a prescribed amount.
Petitioner, like the taxpayer in Johnson, has not shown that he
made any expenditure that fits within these exceptions. Johnson
v. Commissioner, supra at 228 n.11.
Section 274(d) imposes stringent substantiation requirements
for the deduction of travel expenses. Taxpayers must
substantiate by adequate means certain elements in order to claim
deductions, such as the amount of such expenditure, the date of
the expenditure or use, the place of each separate expenditure,
and the business purpose for an expenditure or use. Sec. 274(d);
sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985). To substantiate a deduction by means of adequate
records, a taxpayer must maintain an account book, diary, log,
statement of expense, trip sheets, and/or other documentary
evidence, which, in combination, are sufficient to establish each
element of expenditure or use. The log must be made at or near
the time of the expenditure. Sec. 1.274-5T(c)(2)(i) and (ii),
Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
Petitioner claimed that he prepared a log listing his travel
expenses at or near the times of the expenditures. We are not
required to accept petitioner’s self-serving statements.
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Our review of
this log leads us to conclude it was prepared at one time, and
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