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established that his use of the vehicle satisfied the
requirements of section 162, the logs he provided listing the
business miles he drove do not meet the substantiation
requirements of section 274(d), because petitioner did not
provide the total mileage for all use of the automobile during
the taxable period. Therefore, petitioner’s transportation
expenses do not meet the trade or business requirement of section
162, or the substantiation requirements of section 274(d), so he
is not entitled to deduct his transportation expenses as Schedule
A unreimbursed employee expenses.
B. Tax Preparation Fees
A taxpayer may be allowed a deduction for ordinary and
necessary expenses paid or incurred during the taxable year in
connection with the determination, collection, or refund of any
tax. Sec. 212(3). Petitioner claimed a deduction for tax
preparation fees of $375 as a miscellaneous deduction on Schedule
A. At trial, respondent conceded that petitioner was allowed
$250 of the claimed deduction, so we do not further address this
amount.
Petitioner claims that he purchased Turbo Tax software for
$125 to prepare his return for tax year 2003, after his taxes
were not prepared satisfactorily by a professional tax preparer.
Petitioner admitted at trial that he did not know how much Turbo
Tax cost and that the $125 was an estimate. Petitioner presented
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