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“a high degree of probative value to elevate such statement and
evidence to the level of credibility” of a contemporaneous
record. Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., supra.
Thus, no deduction for expenses under section 274(d) may be
allowed on the basis of any approximation or the unsupported
testimony of the taxpayer. See, e.g., Murata v. Commissioner,
T.C. Memo. 1996-321; Golden v. Commissioner, T.C. Memo. 1993-602.
Petitioner did not keep a handwritten log of his travel and
meals. In order to substantiate his claimed business travel for
2002, petitioner offered into evidence the typed summary of his
travel and an information sheet from his employer showing trips
to job sites. The typed summary, as stated before, shows the
number of round trips made from petitioner’s home to the job
sites, the round-trip mileage, and the meal expenses paid. There
are no receipts in the record indicating meal expenses. In
addition, the Court cannot determine what the numbers on the
information sheet from petitioner’s employer indicate. Further,
petitioner did not explain the information sheet, nor did he
testify as to its contents. Petitioner received $35 as
reimbursement from his employer for every day he traveled to a
nongovernment work site, such as Baltimore, Maryland, or Union
Bridge, Maryland. The $35 was to reimburse him for gasoline
expenses and meal expenses paid during work-related travel.
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