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averaged expenses as his substantiation for the portion of 1992
preceding the theft.
As to the Mercedes automobile, petitioner did not maintain,
nor did he prepare for use at trial, a log chronicling his
business use of the automobile during 1992. Petitioner maintains
that, since the car was used exclusively for business purposes, a
log was not necessary.6
With respect to the meals and entertainment expenses,
petitioner did not maintain a contemporaneous log for such
expenses, although he offered into evidence at trial a stack of
receipts in substantiation of these expenses. He also submitted
a three-page listing of the dates, location, "person seen",
matters "discussed", and the amounts for each event. This
document is also entitled "Reconstruction of Meals Entertainment
Log". Petitioner explained that the amounts shown were not a
complete listing because his practice was to keep receipts on his
person, and, every week or so, he would enter the transactions on
6 The Court notes that, in arguing that this vehicle was
used exclusively for business, petitioner did not address at
trial whether the car was also used for commuting to and from his
place of business, and whether petitioner considered such use as
business use. From the evidence adduced at trial, it is likely
that petitioner may have used the Mercedes for commuting because
petitioners had one other vehicle, and, since Mrs. Hentges was
gainfully employed during 1992, the probability appears to be
that she used the other vehicle for her commuting, and petitioner
used the Mercedes for his commuting. The use of a vehicle for
commuting to and from work is a personal use, and the expense
related thereto is rendered nondeductible by sec. 263.
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