- 30 - 1990 mileage of the Cougar, we cannot allocate the expenses between business and personal use. Petitioner's repair deductions are, therefore, denied. Section 274(d) also applies to travel expenses. Petitioner has failed to prove its business purpose for the $48.77 travel expenses incurred in 1989. Section 274(d) requires substantiation of the business purpose for each item. Sec. 274(d)(2). Petitioner submitted a receipt from the Madonna Inn in San Luis Obispo, California, for the night of December 27, 1989, and Byrne's mileage logs indicate that he drove to San Luis Obispo on that date, but for that particular trip the logs do not indicate a business purpose. As for the remainder of petitioner's expenses--fees of Charles, management fees of Byrne, rents, other insurance, telephone, subscriptions, other office expenses, other professional services, and other travel expenses--totaling $5,978.96 and $9,463.30 for 1989 and 1990, respectively, we find that petitioner has proven its business purpose. We therefore allow them to the extent substantiated; i.e., $3,151.91 and $6,963.05 for 1989 and 1990, respectively. The unsubstantiated expenses are supported only by petitioner's books. We have already found them unreliable, and we therefore deny those deductions.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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