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On the proposed Form 1040, petitioner claims that he is
entitled to a deduction of $2,122 for vehicle expenses, $52 for
other traveling expenses, and $737 for overnight travel expenses.
Petitioner admits that he did not maintain an accurate
mileage log but asserts that he is entitled to a deduction for
mileage while working as an employee of The Men’s Warehouse
because his employment frequently required him to drive to other
locations. This evidence does not satisfy the strict
substantiation requirement of section 274(d).
Petitioner provided receipts and other evidence that he
traveled away from home in 2003. But did not offer any testimony
or other evidence as to whether these expenditures had any
business purpose and provided only minimal evidence as to the
time spent away from home. Furthermore, petitioner did not offer
any testimony or other evidence that his employer did not
reimburse him for his travel expenses. Petitioner has not met
his burden, and we allow no deduction for these transportation
and travel expenses.
2. Business Gifts
Petitioner seeks to deduct $165.14 for business gifts.
Under section 274(b), a taxpayer may not claim a deduction under
section 162 for any expenses for gifts made directly or
indirectly to any individual to the extent the value of the gifts
exceeds $25. To substantiate expenses relating to gifts, a
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