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Camery [sic] (New) $19,850.00”. There is a prior entry on that
same “Balance Sheet” for an unidentified automobile, as follows:
Automobile 1,500
Accumulated Depreciation 1,000 500
Petitioner contends that he used the 1999 Toyota Camry
“almost 100 percent” of the time (“well, maybe 90 percent” of the
time) for business, and that he used a second “old car”
automobile for personal purposes (e.g., to transport his son
during visitations). However, petitioner failed to support such
contention; indeed, petitioner failed to produce (and as we
understand, failed to maintain) records required by section
274(d) related to the use of any automobile. As previously
discussed, such records are essential for any deduction claimed
in respect of listed property such as a passenger automobile.
Similarly, petitioner failed to produce (and as we
understand, failed to maintain) records required by section
274(d) related to the use of any computer or peripheral
equipment. Again, such records are essential for any deduction
claimed in respect of listed property such as a computer or
peripheral equipment.
Finally, petitioner should understand: The fact that a
taxpayer claims a deduction on an income tax return is not
sufficient to substantiate the deduction claimed on that return.
Wilkinson v. Commissioner, 71 T.C. 633, 639 (1979); Roberts v.
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