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that the expenses be substantiated in accordance with the
requirements of section 274. Secs. 162(a), 274(d).
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
approximation or the unsupported testimony of the taxpayer.
Bradley v. Commissioner, T.C. Memo. 1996-461; Golden v.
Commissioner, T.C. Memo. 1993-602. In any event, under section
162(a), petitioners are not entitled to deduct expenses for which
they have been or could have been reimbursed. Orvis v.
Commissioner, 788 F.2d 1406 (9th Cir. 1986) (deduction not
allowable to the extent that the employee is entitled to
reimbursement from the employer), affg. T.C. Memo. 1984-533;
Lucas v. Commissioner, 79 T.C. 1, 7 (1982) (same); Kennelly v.
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