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certain unidentified travel purposes to be deductible, such
expenditures must satisfy the requirements of not only section
162(a) but also section 274(d). To the extent that petitioner
carries his burden of showing that such claimed expenditures
satisfy the requirements of section 162(a) but fails to satisfy
his burden of showing that such expenditures satisfy the
recordkeeping requirements of section 274(d), petitioner will
have failed to carry his burden of establishing that he is
entitled to deduct such expenditures, regardless of any equities
involved. See sec. 274(d); sec. 1.274-5T(a), Temporary Income
Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
The recordkeeping requirements of section 274(d) will
preclude petitioner from deducting expenditures otherwise allow-
able under section 162(a)(2) for the use of his automobile,
lodging, meals, and certain unidentified travel purposes unless
he substantiates the requisite elements of each such expenditure
or use. See sec. 274(d); sec. 1.274-5T(b)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). A taxpayer is
required to
substantiate each element of an expenditure or use
* * * by adequate records or by sufficient evidence
corroborating his own statement. Section 274(d) con-
templates that a taxpayer will maintain and produce
such substantiation as will constitute proof of each
expenditure or use referred to in section 274. Written
evidence has considerably more probative value than
oral evidence alone. In addition, the probative value
of written evidence is greater the closer in time it
relates to the expenditure or use. A contemporaneous
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