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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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