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Petitioner testified that 90 percent of the Lincoln's use
related to the Harwichport property. He produced nothing to
corroborate that testimony, and he failed to explain how he
arrived at that figure. Petitioner produced a chart to show the
number of days he spent in Harwichport. Petitioner appears to
have constructed the chart using the receipts from purchases made
in Harwichport, assuming that he must have been in Harwichport
when he made the purchases. However, petitioner also appears to
contend that if there was no receipt, then he was not in
Harwichport, and he must have returned to Wallingford and
incurred travel expenses in doing so. Petitioner's contention is
a non sequitur that overstates the number of round trips from
Wallingford to Harwichport. It seems more likely that he was in
Harwichport on a number of days when he did not purchase
anything. As for meal expenses, petitioner used the number of
days shown on his chart along with a ballpark figure of $11 for
meals per day to calculate his meal expenses. Although it seems
clear that petitioner had some expenses for meals and travel
between Wallingford and Harwichport, he has failed to prove the
number of trips to Harwichport, the amount spent on meals and
travel, the percentage use of the Lincoln, and he failed to
maintain a log or other record as required by section 274(d).
Accordingly, we sustain respondent's disallowance of the travel
expenses.
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