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be sufficient evidence in the record to permit us to conclude
that a deductible expense was paid or incurred in at least the
amount allowed, Williams v. United States, 245 F.2d 559, 560-561
(5th Cir. 1957).
In the case of travel expenses and expenses relating to the
use of listed property, including any passenger automobile or
other property used as a means of transportation, sec.
280F(d)(4)(A)(i) and (ii), section 274(d) imposes stringent
substantiation requirements to document the nature and amount of
such expenses. Sec. 274(d); Sanford v. Commissioner, 50 T.C.
823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969);
sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985). To meet these substantiation requirements, the
taxpayer must maintain adequate records or sufficient
corroborating evidence to establish each element of an
expenditure. Sec. 274(d); sec. 1.274-5T(b)(6), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985); sec. 1.274-
5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov.
6, 1985).
2. Schedule C Deductions
Section 162(a) allows a deduction for all ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business.
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