Ibrahim Keita - Page 11

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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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