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requirements apply. Section 274(d) disallows deductions for
traveling expenses, gifts, and meals and entertainment, as well
as for listed property, unless the taxpayer substantiates by
adequate records or by sufficient evidence corroborating the
taxpayer's own statement: (1) The amount of the expense,
(2) the time and place of the expense, (3) the business purpose
of the expense, and (4) the business relationship to the taxpayer
of the persons involved in the expense. The term "listed
property" is defined in section 280F(d) and includes passenger
vehicles. See sec. 280F(d)(4)(A)(i).
Under section 274(d), substantiation by means of adequate
records requires a taxpayer to maintain a diary, a log, or a
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
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