Strict Substantiation Required For Unreimbursed Employee Business Expenses.

The petitioner traveled in his personal vehicle for his employer and was not reimbursed for his expenses.  He wrote down his mileage and claimed that 10 percent of his vehicle use was personal, and deducted the balance on Form 1040.  The IRS denied the deduction based on the strict substantiation requirements of I.R.C. Sec. 274(d) because the petitioner did not record the amount, time or business purpose of each business use of the vehicle.  The court, agreeing with IRS, denied the deduction.  Garza v. Comr., 2014 T.C. Memo. 121.