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Against this background, we now analyze whether petitioner
satisfied the strict substantiation requirements of section 274
to allow him to deduct automobile expenses and meals and
entertainment expenses. Petitioner claims that he kept adequate
records and receipts to substantiate his automobile expenses and
his meals and entertainment expenses. Respondent argues that
petitioner failed to satisfy the strict substantiation
requirements because, among other reasons, petitioner failed to
maintain written records of each business trip and petitioner
failed to record the information contemporaneously with the
expenditures. We agree with respondent.
Automobile Expenses
Petitioner claimed $l5,741 of automobile expenses or 48,434
miles as business-related miles. To substantiate the claimed
automobile expenses, petitioner testified that he read the car’s
odometer each day and recorded the business mileage. Petitioner
then entered this information onto the mileage spreadsheet that
was introduced into evidence. The mileage spreadsheet listed the
trips petitioner took, the number of miles for each, and the
clients he visited on those dates. Petitioner introduced no
written documentation to corroborate these entries. Instead,
petitioner testified that he discarded all notes, records, or
other documentation in his quest to have a paperless office.
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Last modified: May 25, 2011