- 3 -
During the year at issue, petitioner, accompanied by his
then wife Ms. Perry, used the motor home for the purpose of
taking trips to various locations in Oregon. They used the motor
home to reach their destination, and they slept and ate in the
motor home during the course of those trips. The trips that
petitioner and Ms. Perry took during 1989 were for the purpose of
personal pleasure and recreation and were not business related.
During 1989, petitioner did not at any time operate the motor
home as a rental property.
During 1989, petitioner maintained a two-page handwritten
log, entitled "MILAGE [sic] RECORDS For 1989" (mileage log), in
which he recorded the following at the time he purchased gasoline
for the motor home: The date of the purchase of gasoline, the
city in which it was purchased, the odometer reading of the motor
home, the generator use of the motor home, the number of gallons
of gasoline purchased, the dollar amount paid for the purchase of
gasoline, and other miscellaneous motor home expenses, such as
propane refills. The mileage log did not in any way indicate
that there was any business purpose for the trips that petitioner
and Ms. Perry took in, or for any other use of, the motor home
during 1989.
During 1989, petitioner also maintained a handwritten log
(handwritten log) consisting of 61 pages of notes that described
in detail the trips that he and Ms. Perry took in the motor home
during that year. In that handwritten log, petitioner noted that
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011