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satisfy the strict substantiation requirements of section 274(d).
See Whalley v. Commissioner, supra; see also sec. 280F(d)(1);
sec. 1.179-1(d)(3), Income Tax Regs. In order to substantiate
the amount of an automobile expense the taxpayer must prove the
following: (1) The amount of the expenditure (i.e., cost of
acquisition); (2) the amount of each business use and the amount
of its total use by establishing the amount of its business
mileage and total mileage; (3) time (i.e., the date of the
expenditure or use); and (4) the business purpose for the
expenditure or use. See sec. 1.274-5T(b)(6)(i) through (iii),
Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
The taxpayer may substantiate the amount of mileage by adequate
records or sufficient evidence that corroborates his statements.
See sec. 274(d). A record of the mileage made at or near the
time of the automobile’s use that is supported by documentary
evidence has a high degree of credibility not present with a
subsequently prepared statement. See sec. 1.274-5T(c)(1)-(3),
Temporary Income Tax Regs., supra.
Petitioner’s evidence consisted of the spreadsheet listing
the numbers he put on his return and his testimony that he
purchased the Jeep from a bankruptcy trustee for $2,200 to use in
his business. Additionally, petitioner testified that the Jeep
was his only vehicle and that his wife did not own a vehicle.
Petitioner failed to establish his business use. Moreover, he
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