- -16
year at issue. Amounts charged for gasoline and related items
totaled $835.20, though it is unclear whether these amounts
correspond to Mr. Velinsky's use of the Ford Thunderbird for
business use. To substantiate the repairs expense of $2,100,
petitioner offered into evidence repair bills totaling $87.70,
accompanied by a money order for $876, and canceled checks for
automobile repair services in the amount of $1,559.83. However,
it is unclear from these documents whether the repair expenses
were for the Ford Thunderbird, or which canceled checks
correspond to which repair bills. Petitioner testified that Mr.
Velinsky often used the Ford Thunderbird for travel purposes in
his band management business, particularly for driving his bands
to their performances and for watching other bands perform,
though petitioner was unsure of the actual miles driven by Mr.
Velinsky for business. Mr. Paquette testified that Mr. Velinsky
had informed him that he had taken eight long-distance trips
during 1990 for business purposes. The parties stipulated to a
statement given by Mr. Velinsky to the IRS which confirmed this
fact and from which we made a finding. The miles which Mr.
Velinsky drove on these trips would approximate 7,000. The
record shows that most of Mr. Velinsky's driving was local and
included driving his bands to their performances or to watch
performances of other bands, rather than driving from one city to
another. We are convinced that Mr. Velinsky used the Ford
Thunderbird in his business, although petitioner has not shown
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