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of her duties at Gastroenterology, and she was compensated for
such travel at the rate of 27 cents per mile. However,
Mrs. Bradley also claimed a $3,549 deduction for her vehicle
expenses as an unreimbursed employee business expense on Schedule
A and Form 2106 (Employee Business Expenses) attached to
petitioners' 1991 Form 1040. Mrs. Bradley calculated the
deduction by taking the product of her actual vehicle expenses
for 1991 and the business use percentage of her automobile. The
deduction was calculated as follows:
Expenses
Gasoline, oil, repairs, vehicle insurance, etc. $1,283
Depreciation expense 2,660
Total 3,943
Multiplied by business use percentage 190%
Vehicle expense claimed 3,549
1Business use percentage = 11,428 business use miles /
12,698 total miles = 90%.
Mrs. Bradley also claimed a $375 deduction for the cost and
maintenance of uniforms as an unreimbursed employee business
expense on Schedule A and Form 2106 attached to petitioners' 1991
Form 1040.
Finally, petitioners also claimed a $4,640 deduction for
charitable contributions on Schedule A. Petitioners presented
receipts or canceled checks for only $205 of this amount.
Respondent determined that petitioners could deduct only
$1,773 of their claimed vehicle expenses. The remaining expenses
were not deductible because petitioners could have been or
actually were reimbursed for such expenses. Alternatively,
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