Matthew P. Brown - Page 4

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               Petitioner drove his automobile to visit existing and                  
          potential customers.  From the beginning of 2001 until November             
          16, 2001, petitioner utilized his Honda Accord (Honda) for both             
          his business and personal transportation.  On or after November             
          16, 2001, petitioner utilized a Nissan Maxima (Nissan) for all of           
          his transportation.  Petitioner estimated use of his automobile             
          as approximately 20 percent personal and the remainder business.            
          Petitioner calculated his mileage expense for each of the years             
          in issue by reviewing the odometer of his automobile and                    
          designating a percentage of the miles driven as business miles.             
               Petitioner submitted weekly activity reports to his                    
          employer.  Petitioner submitted to the Court copies of weekly               
          activity reports for approximately 15 weeks for 2001 and for the            
          entire year 2002.  The weekly activity reports do not reflect the           
          number of miles driven, nor do they contain other details as to             
          specific business activity.  Petitioner maintained a day planner;           
          however he lost the planner for 2001 sometime in early 2002.                
          Petitioner did not retain his day planner for 2002.                         
               On his 2001 Federal income tax return, petitioner reported             
          wages of $59,358 and claimed itemized deductions on Schedule A,             
          Itemized Deductions, of $20,157.  The claimed itemized deductions           
          consisted of $19,807 of employee business expenses and $350 of              
          gifts to charities.  On his 2002 Federal income tax return                  
          petitioner claimed itemized deductions of $9,091, consisting of             






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