The case: T had several businesses for which he deducted substantial vehicle expenses against his business income. The IRS denied the deductions for lack of substantiation.

Held: For the IRS. The taxpayer’s detailed spreadsheets of business use of his vehicles to support the expense deductions were not recorded when the trips were taken. They were assembled from memory only after he was audited, so the IRS questioned the vehicle deductions. Nor did he provide any calendars, logs, receipts or other documents to support the entries in the spreadsheets.

The court ruled that the taxpayer failed to keep contemporaneous records of the business vehicle use deductions required under §274, Disallowance of certain entertainment, etc., expenses, and denied all of them. [Hatte v. Commissioner, T.C. Memo 2019-109]