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in or around Keyser where petitioners resided. Mr. Shoemaker’s
decision to drive from petitioners’ residence in Keyser to his
claimed job site locations arose solely from petitioners’ per-
sonal choice to live in Keyser. Petitioners could have chosen to
reduce their automobile expenses by living closer to Mr. Shoe-
maker’s claimed job site locations. They did not do so for
personal reasons.
On the instant record, we find that petitioners have failed
to carry their burden of establishing that during 2002 the ex-
penses relating to Mr. Shoemaker’s use of petitioners’ automobile
that petitioners claim he incurred while traveling from petition-
ers’ residence to his claimed job site locations were incurred
for business, and not personal, reasons.14
On the record before us, we find that petitioners have
failed to carry their burden of establishing that they are enti-
tled for their taxable year 2002 to the deduction under section
162(a) that they claim for expenses relating to Mr. Shoemaker’s
use of their automobile.15
14See, e.g., Daiz v. Commissioner, supra; Epperson v. Com-
missioner, supra.
15Assuming arguendo that petitioners had established the
deductibility under sec. 162(a) of the claimed expenses relating
to Mr. Shoemaker’s use of their automobile, they would still have
to satisfy the requirements of sec. 274(d). We concluded above
that we shall not rely on document one or document two to estab-
lish petitioners’ position with respect to any of the claimed
expenses, including the expenses relating to Mr. Shoemaker’s use
(continued...)
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