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838 (1973); Commissioner v. Flowers, 326 U.S. 465 (1946); secs.
1.162-2(e), 1.262-1(b)(5), Income Tax Regs. Automobile mileage
deductions are also subject to the strict substantiation
requirements of section 274(d).
Transportation expenses between a home office and another
place of business, however, may be deductible if the home office
is the taxpayer’s principal place of business. Strohmaier v.
Commissioner, 113 T.C. 106, 113-114 (1999); Curphey v.
Commissioner, 73 T.C. 766, 777-778 (1980); Gosling v.
Commissioner, T.C. Memo. 1999-148.
Where a taxpayer shows that his automobile expenses satisfy
the requirements of section 162 but fails to establish that his
records satisfy the heightened substantiation requirements of
section 274(d), the expenses will not be allowed. To
substantiate such expenses, the taxpayer must provide the
following adequate records or sufficient evidence to corroborate
his own testimony: (1) The amount of the expenditures; (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).
For the reasons discussed supra, petitioner’s residence was
not his principal place of business. Even if petitioner had
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Last modified: November 10, 2007