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274(d). See Sanford v. Commissioner, supra at 827; sec. 1.274-
5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6,
1985).
Petitioner’s position throughout this case has been that he
has adequately substantiated his Schedule C expenses because his
business records were destroyed and because he has stated under
oath that the expenses he claimed on his Schedule C were correct.
That position is wrong, and we reject it. While we accept as
true the fact that petitioner kept some records and that the
records were lost or destroyed as a result of the actions of
petitioner’s former employer, petitioner still had an obligation
to substantiate his deductions. Petitioner made no effort to
reconstruct his records or to submit any documentation to assist
us in evaluating the credibility of his sworn statements.
Even if we assume for purposes of argument that petitioner
incurred ordinary and necessary business expenses in connection
with his trucking activity, petitioner has not provided us with a
reasonable evidentiary basis upon which to estimate those
expenses. Petitioner testified at trial in very general terms
regarding his advertising, fuel, broker’s commission, cell phone,
insurance, licenses and taxes, repairs, and rental expenses, but
the testimony did not provide sufficient detail to permit us to
estimate his expenses in these categories. Petitioner offered no
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