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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. 1.274-
5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov.
6, 1985).
Taxpayers may use a standard mileage rate established by the
Internal Revenue Service in lieu of substantiating the actual
amount of the expenditure. See sec. 1.274-5(j)(2), Income Tax
Regs. The standard mileage rate is generally multiplied by the
number of business miles traveled. See Rev. Proc. 2002-61, 2002-
2 C.B. 616 (in effect for transportation expenses incurred during
2003). The use of the standard mileage rate establishes only the
amount deemed expended with respect to the business use of a
passenger automobile. Sec. 1.274-5(j)(2), Income Tax Regs. The
taxpayer must still establish the actual mileage, the time, and
the business purpose of each use. Nicely v. Commissioner, T.C.
Memo. 2006-172; sec. 1.274-5(j)(2), Income Tax Regs.
Petitioners introduced a transcript from Dakota County
Technical College indicating that Mr. Farran took a variety of
courses in 2003, including hydraulics, industrial electronics,
and motor controls. Mr. Farran testified that he did not receive
a degree from Dakota County Technical College but testified that
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