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taxpayer must still establish the actual mileage, the time, and
the business purpose of each use. Nicely v. Commissioner, T.C.
Memo. 2006-172; sec. 1.274-5(j)(2), Income Tax Regs.
Petitioner submitted a travel log, consisting of a
collection of preprinted forms which he had filled in, showing
the details of travel on particular dates. The travel log was
not prepared contemporaneously with the claimed business travel
but rather was a reconstruction based on petitioner’s
recollection of travel during 2003. The travel log was prepared
after petitioner had been contacted by respondent’s agents in
connection with an audit of petitioner’s 2003 tax return. The
travel log was unsupported by any other documentation, such as a
calendar or receipts, and petitioner admitted that the log
contained several errors. Even if petitioner maintained an
office in his home for the convenience of the university (which
we find he did not), the travel log does not meet the
substantiation requirements of section 274, and petitioner’s use
of his automobile for his trips to libraries around the State did
not generate any business deduction.6
Petitioner’s claimed transportation expenses reflecting the
use of his vehicle to drive from his home to the university were
6At trial, respondent conceded that other expenses for trips
out of State and abroad for the purpose of attending conferences
and the like are adequately substantiated and are therefore
deductible.
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