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short, petitioner has not met the substantiation requirements of
section 274(d). Section 1.274-5T(a), Temporary Income Tax Regs.,
50 Fed. Reg. 46014 (Nov. 6, 1985), provides that a taxpayer shall
not be allowed a deduction based on approximation or the
taxpayer’s unsupported testimony. Accordingly, we hold that
petitioner is entitled to a mileage deduction limited to the
miles set forth on the job worksheets.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007