James A. and Joan H. Soholt - Page 20




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          introduced a letter from the MetLife Regional Marketing Director            
          indicating that Mr. Soholt was not reimbursed for laptop charges.           
          We find that the evidence petitioners introduced on this issue,             
          taken together, satisfies the strict substantiation requirements.           
          Accordingly, petitioners are entitled to deduct $795 of equipment           
          costs for the laptop.                                                       
          Automobile Expenses                                                         
               Petitioners claimed $6,112 of automobile expenses for 2003.            
          Passenger automobiles are listed property under section 280F and            
          strict substantiation is therefore required.  Sec. 274(d).  No              
          deduction is allowed for any travel expense unless the taxpayer             
          substantiates by adequate records or by sufficient evidence                 
          corroborating the taxpayer’s own statement the amount of the                
          expense, the mileage for each business use of the automobile and            
          the total mileage for all use of the automobile during the                  
          taxable period, the date of the business use, and the business              
          purpose for the use.  Sec. 1.274-5T(b)(6), Temporary Income Tax             
          Regs., supra.  Adequate records include the maintenance of an               
          account book, diary, log, statement of expense, trip sheets,                
          and/or other documentary evidence, which, in combination, are               
          sufficient to establish each element of expenditure or use.  Sec.           
          1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017           
          (Nov. 6, 1985).                                                             








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