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for the proposition that the cost of travel between a taxpayer’s
two places of business is business travel. Petitioners’ reliance
on Heape is misplaced. In Heape, the taxpayer was a coal miner
who also operated a farm. We held that, even though the taxpayer
did a considerable amount of work on his farm, he could not
deduct his expenses of traveling between the coal mine and his
home because, as here, the primary purpose for the trips was
personal.
Petitioners also rely on Gosling v. Commissioner, T.C. Memo.
1999-148, and Genck v. Commissioner, T.C. Memo. 1998-105.
Petitioners’ reliance on Gosling and Genck is misplaced. In
those cases, we held that the taxpayers could deduct the cost of
travel between a business the principal location of which was at
their home and a second location for the same business. In
contrast, the Fritchton property was not the principal place of
business of the gift shop.
We conclude that the primary reason for petitioners’ travel
between their gift shop and the Fritchton residence was personal.
See Commissioner v. Flowers, supra.
3. Substantiation
Petitioners’ only evidence of the amount of business use of
the Cadillac and the Corvette in 1994 was petitioners’ testimony.
Petitioner testified that his use of the Cadillac was 95 percent
business and 5 percent personal. Petitioners treated the trips
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