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taxpayer’s own statement.” Sec. 274; sec. 1.274-5T(c)(1) and
(3)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,
1985). That requirement is satisfied where a taxpayer presents
both his own statement containing specific information in detail
as to the element, as well as other corroborative evidence
sufficient to establish the element. Sec. 1.274-5T(c)(3)(i),
Temporary Income Tax Regs., supra. Generally, the corroborative
evidence must be direct evidence, such as a statement in writing
or the oral testimony of witnesses involved in the deductible
event, or documentary evidence such as described in section
1.274-5T(c)(3), Temporary Income Tax Regs., 50 Fed. Reg. 46020
(Nov. 6, 1985). In proving the business purpose of an
expenditure, the corroborative evidence may be circumstantial
evidence. Sec. 1.274-5T(c)(3)(i), Temporary Income Tax Regs.,
supra.
In lieu of substantiating the actual amount of an
expenditure relating to the business use of a passenger
automobile, a taxpayer may use a standard mileage rate
established by the Internal Revenue Service. See sec. 1.274-
5(j)(2), Income Tax Regs.; Rev. Proc. 98-63, 1998-2 C.B. 818.
Use of the standard mileage rate establishes the amount deemed
expended with respect to the business use of a passenger
automobile, but such use does not relieve a taxpayer of his
burden of substantiating the other elements required by section
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