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prepared contemporaneously with the travel. Petitioner testified
that he kept the travel records in an effort to determine, during
2003, whether the income from his consulting activity was
sufficient to cover his expenses.
Section 274 provides that expenses paid or incurred with
respect to travel and certain listed property are deductible only
if the taxpayer meets the stringent substantiation requirements of
section 274(d). See sec. 280F(d)(4)(A). For these expenses, only
certain types of documentary evidence will suffice. Passenger
automobiles are listed property under section 280F, and therefore
strict substantiation for their use as transportation is required.
Sec. 274(d). No deduction is allowed for any travel or
transportation expense unless the taxpayer substantiates by
adequate records or by sufficient evidence corroborating the
taxpayer’s own statement the amount of the expense, the mileage
for each business use of the automobile and the total mileage for
all use of the automobile during the taxable period, the date of
the business use, and the business purpose for the use. Sec.
1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016
(Nov. 6, 1985). Adequate records include the maintenance of an
account book, diary, log, statement of expense, trip sheets,
and/or other documentary evidence, which, in combination, are
sufficient to establish each element of expenditure or use. Sec.
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