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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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