Stanley A. and Connie A. Wasik - Page 19




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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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