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1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017
(Nov. 6, 1985).
Petitioner submitted a travel log consisting of 12 pages, one
for each month of 2003. The purpose for the claimed travel
expense is indicated on every page as “Travel from Niles to
Steubenville and return” or “Travel from Niles to
Steubenville/Lisbon et al and return”. The description of the
travel is shown on every page as “Client calls at
Chamber/Commerce” and/or “Client calls at One Stop Center”.
Actual travel on specific days is not shown; rather, monthly
totals are given. Specific client names are not provided (or
itemized with identifying information redacted). The nature of
the business discussions petitioner conducted is not shown. We
are unable to conclude from petitioner’s travel log that the
strict substantiation requirements of section 274 have been met.
Accordingly, the claimed mileage/travel expenses are not
deductible.
At trial, petitioner claimed that he is entitled to a
deduction for “lost medical insurance coverage”. Petitioner
testified that during 2003 he did not have insurance coverage and
did not pay any amounts for medical insurance. His claimed
deduction is based on amounts he estimated that he would have paid
if he had purchased such insurance. Because petitioner did not
pay this expense, he is not entitled to this deduction.
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