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satisfy the requirements of section 274(d) and the regulations
cited. Mr. Viar used his vehicle for a number of purposes,
including commuting, business, and personal travel. He
admittedly failed to maintain logs or contemporaneous records of
his mileage or the amount, time, place, and business purpose of
his trips. After petitioners were audited, Mr. Viar
“reconstructed” his mileage for the different purposes based on
his annual odometer readings. Similarly, Mr. Viar did not keep a
contemporaneous record of his meals and entertainment expenses
detailing the times he provided such services for real estate
clients and other business colleagues. He reconstructed these
expenses from credit card statements.
The Court is not bound to accept petitioners’ uncorroborated
or self-serving testimony. Tokarski v. Commissioner, 87 T.C. 74,
77 (1986). Moreover, to the extent petitioner used his vehicle
to commute to and from work, such expenses are considered
nondeductible personal living expenses. Sullivan v.
Commissioner, 45 T.C. 217 (1965), affd. 368 F.2d 1007 (2d Cir.
1966); sec. 1.262-1(b)(5), Income Tax Regs. The Court holds that
the car and truck expenses and travel, meals, and entertainment
expenses at issue were not properly substantiated under the cited
legal standards. Petitioners, therefore, are not entitled to
deductions in excess of amounts allowed by respondent for their
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