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contrast, she contends that she is entitled to a deduction for
the use of the Suburban.
In the case of a passenger automobile, section 274(d)
proscribes a deduction on the basis of any approximation or the
unsupported testimony of the taxpayer. Sec. 274(d)(4), sec.
280F(d)(5). The term “passenger automobile” is defined as any 4-
wheeled vehicle that is manufactured primarily for use on public
streets, roads, and highways and that is rated at 6,000 pounds
unloaded gross vehicle weight or less. Sec. 280F(d)(5)(A).
Although the term “passenger automobile” does not include any
truck or van under regulations promulgated by the Commissioner,
see sec. 280F(d)(5)(B), petitioner failed to demonstrate that the
Suburban comes within the definition of an excepted truck or van,
see sec. 1.280F-6T(c)(3)(iii), Temporary Income Tax Regs., 49
Fed. Reg. 42713 (Oct. 24, 1984); sec. 1.274-5T(k)(2), Temporary
Income Tax Regs., 50 Fed. Reg. 46033 (Nov. 6, 1985).
Even if the stringent substantiation requirements of section
274(d) were not applicable, and even if we were to conclude that
petitioner incurred deductible expenses for the use of a vehicle
owned by another taxpayer, the record provides no basis
whatsoever for us to estimate a reasonable allowance for the use
of the Suburban. See Williams v. United States, 245 F.2d 559,
560 (5th Cir. 1957); Vanicek v. Commissioner, 85 T.C. 731, 743
(1985).
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