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passenger automobile. Sec. 280F(d)(4)(A)(i). Cellular phones
are also included in “listed property” for purposes of sections
274(d)(4) and 280F(d)(4)(A)(v) and are thus subject to the strict
substantiation requirements. Gaylord v. Commissioner, T.C. Memo.
2003-273.
Accordingly, under section 274(d), no deduction is allowable
for expenses incurred with respect to listed property such as a
passenger automobile on the basis of any approximation or the
unsupported testimony of the taxpayer. E.g., Golden v.
Commissioner, T.C. Memo. 1993-602. These stringent
substantiation requirements are designed to encourage taxpayers
to maintain records together with the documentary evidence
substantiating each element of the expense to be deducted. Sec.
1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016
(Nov. 6, 1985).
With respect to petitioner’s claimed vehicle expense
incident to her employment as a physician, we must decide whether
this expense (or any portion thereof) is allowable under sections
162(a) and 274(d) and the regulations thereunder.
Petitioner presented evidence at trial consisting of a
single page of handwritten notations as follows:
Car insurance $1,258.10
Gasoline/fuel 875.39
Car maintenance 615.60
Car repairs 267.50
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