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evidence that in combination are sufficient to establish each
element of an expenditure or use. See sec. 1.274-5T(c)(2),
Temporary Income Tax Regs., supra. A contemporaneous log is not
required, but corroborative evidence to support a taxpayer’s
reconstruction of the elements of expenditure or use must have “a
high degree of probative value to elevate such statement” to the
level of credibility of a contemporaneous record. Sec. 1.274-
5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,
1985).
Petitioner’s documentation for his categories of items that
appear to be for a vehicle, vehicle insurance, and for meals,
travel, and entertainment expenses do not meet the standard of
substantiation required by section 274(d).
The Court is unable to determine from the documents provided
by petitioner that he is entitled to deduct any amount of
business expenses in excess of that conceded by respondent.
Petitioner is entitled to deduct various Schedule C expenses of
$8,106 for 2003.
Earned Income Credit
Petitioner claimed the earned income credit for taxable year
2003 for two “qualifying children”. Respondent determined that
petitioner is not entitled to the earned income credit for 2003.
Section 32(a)(1) allows an eligible individual an earned
income credit against the individual’s income tax liability.
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