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records, together with documentary evidence substantiating each
element of the expense sought to be deducted. Sec. 1.274-
5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,
1985).
Mr. Goode testified that the claimed deduction for car and
truck expenses was based on the standard mileage rate. In lieu of
substantiating the actual amount of an expenditure relating to the
business use of a passenger automobile, a taxpayer may use a
standard mileage rate established by the Internal Revenue Service.
See sec. 1.274-5(j)(2), Income Tax Regs.; Rev. Proc. 2001-54,
supra. Use of the standard mileage rate establishes the amount
deemed expended with respect to the business use of a passenger
automobile, but it does not relieve a taxpayer of his burden of
substantiating the other elements required by section 274 and the
regulations issued thereunder. Sec. 1.274-5(j)(2), Income Tax
Regs.
Petitioners introduced no evidence that would establish the
number of miles the Robco vehicles were driven. There is nothing
in the record that satisfies the substantiation requirements of
section 274. Therefore, we cannot allow the claimed deduction for
car and truck expenses.2
2In any event, petitioners would not have been entitled to
claim the deduction for car and truck expenses in addition to the
insurance expense deduction which we found is allowable.
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