Neal N. and Ruby W. Viar - Page 12

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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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