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complies with certain strict substantiation rules, no deduction
is allowable (1) for traveling expenses, (2) for entertainment
expenses, (3) for expenses for gifts, or (4) with respect to
listed property. Listed property includes passenger automobiles
and other property used as a means of transportation. Sec.
280F(d)(4). To meet the strict substantiation requirements, the
taxpayer must substantiate the amount, time, place, and business
purpose of the expenses. Sec. 274(d); sec. 1.274-5T, Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
In order to substantiate the amount of expenses for listed
property, a taxpayer must establish the amount of business use
and the amount of total use for such property. Sec. 1.274-
5T(b)(6)(i)(B), Temporary Income Tax Regs., 50 Fed. Reg. 46006
(Nov. 6, 1985). With respect to the use of automobiles, in order
to establish the amount of an expense the taxpayer must establish
the amount of business mileage and the amount of total mileage
for which the automobile was used. Id. The taxpayer may
substantiate the amount of mileage by adequate records or by
sufficient evidence corroborating his own statement. Sec.
274(d). A record of the mileage made at or near the time the
automobile was used, supported by documentary evidence, has a
high degree of credibility not present with a subsequently
prepared statement. Sec. 1.274-5T(c)(1), (2), and (3), Temporary
Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
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