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Vehicle Expenses for Travel to Duluth for Training
We now consider whether petitioners are entitled to deduct
vehicle expenses incurred in connection with Mr. Wasik’s training
trip to Duluth.
Passenger automobiles are listed property under section
280F, and strict substantiation is therefore required. Sec.
274(d)(4). No deduction is allowed for any travel expense unless
the taxpayer corroborates 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., 50 Fed. Reg. 46016 (Nov. 6, 1985). Adequate records
include the maintenance of an account book, diary, log, statement
of expenses, 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).
Taxpayers may use a standard mileage rate established by the
Internal Revenue Service in lieu of substantiating the actual
amount of the expenditure. See sec. 1.274-5(j)(2), Income Tax
Regs. The standard mileage rate is generally multiplied by the
number of business miles traveled. See Rev. Proc. 2002-61, 2002-
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