Pennel Phlander Irwin - Page 14

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            served as his writing compound.  As such, the expenses in                                     
            question were nondeductible personal commuting expenses.  Curphey                             
            v. Commissioner, 73 T.C. 766, 777-778 (1980);  Mazzotta v.                                    
            Commissioner, 57 T.C. 427, 429 (1971), affd. per curiam 465 F.2d                              
            1399 (2d Cir. 1972), affd. without opinion 467 F.2d 943 (2d Cir.                              
            1972).                                                                                        
                               (2)  1988 Toyota Pickup                                                    
                  Petitioner's wife (Ms. Irwin) was a teacher who also                                    
            assisted petitioner with his writing activities on a part-time                                
            basis.  Ms. Irwin was the primary driver of a 1988 Toyota pickup                              
            leased by petitioner.  Petitioner claims 1,297 business miles                                 
            driven in 1990, 2,618 in 1991, and 2,164 in 1992.  Apart from                                 
            identifying each log entry as "writing research travel",                                      
            petitioner offers no evidence regarding the business purpose of                               
            any of the miles driven.  As such, we deny petitioner's claims                                
            for deductions with respect to the Toyota pickup.                                             
                        (3)  1990 Toyota Camry                                                            
                  For the years 1991 and 1992, petitioner claims that he used                             
            his 1990 Toyota Camry for business purposes.  The purported                                   
            business mileage is 22,616 for 1991, and 21,850 for 1992.  Of                                 
            these amounts, petitioner's commuting mileage totals 21,806 in                                
            1991, and 21,420 in 1992.  As explained supra, expenses relating                              
            to commuting are nondeductible.  In attempt to substantiate the                               
            remaining mileage, petitioner introduces a copious amount of                                  






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