- 2 - case. The issue for decision is whether petitioner is entitled to deductions for car and truck expenses relating to 2002. Background Petitioner operated a home remodeling business, RTW Contracting. He frequently drove to numerous job sites in his truck, which he used primarily for business purposes. Petitioner maintained job worksheets on which he recorded the date, job site location, names of employees working at the site, work performed, and total number of miles petitioner drove to and from the site. On his 2002 Schedule C, Profit or Loss From Business, petitioner deducted car and truck expenses of $10,878, based on the 2002 standard mileage rate of 36.5 cents per mile for 29,803 business miles. On August 25, 2005, respondent issued petitioner a notice of deficiency denying, due to lack of substantiation, petitioner’s deduction. On November 23, 2005, while residing in St. Louis, Missouri, petitioner filed his petition with the Court. Discussion Section 162 allows a deduction for all ordinary and necessary expenses paid or incurred in carrying on a trade or business. Pursuant to section 274(d), however, certain business expenses are subject to stricter substantiation requirements. Section 274(d) provides that no deduction shall be allowed with respect to any listed property defined in section 280F(d)(4),Page: Previous 1 2 3 4 5 NextLast modified: November 10, 2007