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1.274-5T(b)(3)(i) through (v), Temporary Income Tax Regs., 50
Fed. Reg. 46015 (Nov. 6, 1985).
Petitioner’s evidence consisted of the spreadsheet listing
the numbers he put on his return. Petitioner did not testify as
to his expenses for travel and meals and entertainment nor submit
any receipts to verify his payment of the claimed expenses in
2002. See secs. 446(a), (c), 461(a). The Court finds that
petitioner has not satisfied the strict substantiation
requirements of section 274(d), and therefore, the expenses are
not deductible. Accordingly, respondent’s determinations are
sustained.
D. Truck Purchase as a Section 179 Expense
Section 179(a) generally allows a taxpayer to elect to treat
the cost of section 179 property as a current expense in the year
the property is placed in service, within certain dollar
limitations. If the property is used for both business and other
purposes, then the portion of the property’s cost that is
attributable to the business use is eligible for expensing under
section 179 but only if more than 50 percent of the property’s
use is for business purposes (the predominant use requirement).
See sec. 1.179-1(d), Income Tax Reg.; see also Whalley v.
Commissioner, T.C. Memo. 1996-533. Moreover, in order to claim a
deduction for listed property, which is defined in section
280F(d)(4) to include a passenger automobile, the taxpayer must
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