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records or sufficient evidence to corroborate his own statement.
See sec. 274(d); sec. 1.274-5T(c)(1), Temporary Income Tax Regs.,
50 Fed. Reg. 46016 (Nov. 6, 1985). In order to meet the
“adequate records” requirements, a taxpayer is to maintain an
account book, diary, statement of expenses, or similar record and
documentary evidence (such as receipts, paid bills, or similar
evidence) which, when combined, establish each element of the
expense that section 274(d) requires to be established. Sec.
1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017
(Nov. 6, 1985).
Petitioner presented as evidence bank statements for 2002.
Petitioner also presented a spreadsheet that he prepared,
summarizing and sorting business expenses paid in 2002 according
to category. Respondent agrees that the amounts shown on the
spreadsheet match the amounts stated in the bank statements.
Therefore, the amounts of the expenses, to the extent set forth
in the spreadsheet, are not in dispute.
a. Car and Truck Expenses
Petitioner claimed deductions of $4,910 for car and truck
expenses. Petitioner indicated on the spreadsheet that he paid
car insurance of $1,300.30 and attributed half of that amount to
Zomans Productions. Petitioner has not shown that the car
insurance was for a business rather than a personal purpose.
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