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was entitled to mileage of 2,752.4 Petitioner contends that the
trip to Portland was 4,000 miles.
Petitioner testified that she had a "trip-tic" from AAA
which indicated that the mileage to Portland was 4,000 miles;
however, the trip-tic is now lost. Petitioner presented a repair
bill dated May 15, 1991, the day prior to her departure for
Portland, which indicates an odometer reading of 102,321.
However, nothing in the record indicates petitioner's mileage
upon arrival in Portland. Other than this repair bill,
petitioner presented no other documentation such as a diary, log,
or similar evidence to substantiate her mileage as required by
section 274. Thus, petitioner has failed to substantiate the
additional mileage. Moreover, any portion of the trip that could
be considered for personal purposes, such as a sightseeing side
trip, would not be an ordinary and necessary deductible business
expense. Accordingly, petitioner is not entitled to a deduction
for mileage in excess of the amount previously allowed by
respondent.
We note that petitioner did not claim a deduction for her
return trip to Rochester, but stated that the return trip was
claimed as a portion of Mr. Ganong's job search expenses.
4 Respondent calculated this amount using the mileage from
Rochester, New York, to Buffalo, New York, (78 miles) plus the
mileage from Buffalo, New York, to Portland, Oregon (2,674
miles).
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