- 6 - Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). At a minimum, the taxpayer must substantiate: (1) The amount of the expense; (2) the time and place the expense was incurred; and (3) the business purpose for which the expense was incurred. The strict substantiation requirements of section 274 apply to deductions with respect to “any listed property (as defined in section 280F(d)(4))”. Section 280F(d)(4)(A)(i), in turn, includes “passenger automobile” in the definition of listed property. Further, section 1.274-5T(b)(6)(i)(A), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985), includes the cost of maintenance and repairs for listed property as subject to the section 274 substantiation rules. Petitioners claimed automobile expenses of $3,227; these expenses related to petitioners’ pickup truck. Mr. Stukes testified that some substantiating documents pertaining to the automobile mileage were lost when petitioners moved. However, he introduced a truck mileage log (the mileage log) with 24 entries. The mileage log, which shows that petitioners drove the truck 6,684 miles for farm-related business, was not prepared contemporaneously with the incurrence of the claimed expenses but rather was a reconstruction by petitioners of their use of the truck. The mileage log shows the date of each use and the specific destination (such as Home Depot, Wal-Mart, farm equipment vendors, gas stations, and truck supplies vendors).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007