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numerous mileage entries that conflicted with mileage records on
auto repair bills. Moreover, the pagination of the mileage log
indicated that the entries in the 1991 log may have been written
prior to the entries in the 1990 log. Accordingly, we find
petitioner is liable for the penalties under section 6662(a) for
1990 and 1991 on the portion of the understatements attributable
to the disallowed unreimbursed employee business expenses.
Decision will be entered
under Rule 155.
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