Thomas Edwards - Page 11




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          F.2d 201 (2d Cir. 1969).  Section 274(d) imposes strict                     
          substantiation requirements for, inter alia, traveling expenses             
          and expenses with respect to listed property.  Listed property is           
          defined in section 280F(d)(4) to include passenger automobiles              
          and other property used for transportation.                                 
               Pursuant to section 274(d), a taxpayer must substantiate a             
          claimed automobile expense with adequate records or sufficient              
          evidence corroborating his own testimony as to:  (1) The amount             
          of the expenditure; (2) the mileage for each business use of the            
          automobile and the total mileage for all use of the automobile              
          during the taxable period; (3) the date of the business use; and            
          (4) the business purpose for the use of the automobile.  Sec.               
          1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016              
          (Nov. 6, 1985).                                                             
               Petitioner seeks to deduct expenses for driving to job sites           
          throughout Florida.  The only detail he offers is vague testimony           
          of roughly 100,000 miles driven in 2001.  Aside from his own                
          self-serving testimony and the testimony of Mr. Burrell,                    
          petitioner has not offered any evidence to satisfy the threshold            
          requirement of showing that any transportation expenses were paid           
          or incurred in carrying on a particular trade or business.  A               
          fortiori, such evidence necessarily falls short of meeting the              
          heightened substantiation requisites of section 274.                        








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