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activities. Browning v. Commissioner, 890 F.2d at 1087-1088.
Petitioner has failed to establish that the business use of his
home is within the exception provided in section 280A(c)(1)(A).
As such, petitioner's dwelling unit does not qualify as a home
office, and we deny petitioner's claims for deductions related to
his home.
(B) Car and Truck Expenses
Petitioner claims automobile expense deductions with respect
to three vehicles used during the years 1990, 1991, and 1992.
Petitioner's automobile logs, offered as substantiation for these
expenses, were not prepared contemporaneously. Petitioner claims
that all the vehicles in question were used exclusively for
business purposes.
(1) 1985 Nissan Sentra
For 1990, petitioner claims that he used his 1985 Nissan
exclusively for business purposes. The total mileage for the
year is 23,900 miles. Of this amount, 22,767 miles are travel
between petitioner's teaching job in Sacramento, and his
residence in Lodi.5 We find that petitioner's primary motivation
in traveling between Sacramento and Lodi was to commute to and
from the home where he and his family resided. Petitioner would
have returned to his Lodi residence regardless of whether it also
5 The remaining 1,133 miles relate to travel away from
petitioner's home and are separately discussed infra.
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