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of income in 2002. A payroll statement from Mr. Buah’s other
employer, Landmark Honda, indicates he earned $28,686 in 2002.
The difference between the wages reported on the return and the
amount received from Landmark Honda is $1,140. Mr. Buah did not
explain why he would incur $9,400 of mileage expense for a job
that paid him only $1,140.
We also note that passenger automobiles are “listed
property” under section 280F(d)(4)(A)(i). Thus, the claimed
mileage expenses are subject to the heightened substantiation
requirements of section 274(d). See Romer v. Commissioner, T.C.
Memo. 2001-168. Mr. Buah must substantiate by adequate records
or by sufficient evidence corroborating his own testimony the
amount of the expense, the time and place of the use, and the
business purpose of the use. Sec. 274(d); sec. 1.274-5T(b),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
Although Mr. Buah introduced mileage logs, their reliability
is suspect. It is unclear when the logs were made, and several
entries have been whited out and replaced with other numbers.
Mr. Buah introduced a notarized statement that is somewhat
difficult to read, but which appears to state that Mr. Buah “do
(510) five hundred & ten miles weekly for his routing schedule.
That is, 85 miles per day. Thanks.” The statement is not on
National Delivery Service letterhead, the signature is illegible,
and there is no contact information listed. We do not find this
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