- 14 -
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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