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we find that petitioner made trips to Virginia City on an average
of three times per week during 20 weeks during the year, for a
total of 4,800 miles. At the standard business mileage rate of
28 cents per mile in effect for 1992 under Rev. Proc. 91-67,
supra, petitioner is entitled to a mileage allowance deduction
for local travel of $22.40 per day, or a total of $1,344. We
sustain the balance of respondent's disallowance of petitioner's
claimed car and truck expense deduction.
4. Legal and Professional Expenses of $3,342
Petitioner testified that "primarily" the $3,342 was paid
for production costs and that a "small amount" was for legal
expenses. Petitioner testified that the production costs
included both amounts paid to the production assistant in
Virginia City and amounts paid to sound engineers. Petitioner
testified that he worked with the production assistant to
determine a budget and how much of the fee petitioner would keep
and how much the production assistant would keep. However,
petitioner presented no invoices or other documentation showing
how the services of the production assistant were billed and paid
for. Although petitioner testified that he reported the gross
amounts paid under the contracts, it is not clear--indeed it
seems unlikely--that the production assistant's share was part of
the gross income reported by petitioner. We do not believe that
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