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deduction on the basis of any approximation or the unsupported
testimony of the taxpayer. Sec. 1.274-5T(a), Temporary Income
Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
In 1991, Mrs. Whalley drove 590 miles in connection with
three different business conferences she attended in California.
She took a management class in Monterey, a public service seminar
in San Mateo, and a supervisory skills program in San Jose.
Petitioner's testimony coupled with the documentary evidence
submitted at trial establishes the time and place of the business
conferences, that they were attended by Mrs. Whalley for
business, and that she drove 590 miles to attend them.
Accordingly, petitioners have met the requirements of sections
162 and 274(d) and therefore may deduct the expenses incurred in
connection with such mileage.
For 1991 and 1992, however, we sustain respondent's
determination as to the balance of the 4,110 and 5,278 miles
driven, respectively, by Mrs. Whalley for miscellaneous meetings
that she allegedly attended on behalf of the police department.
The mileage claimed is not supported by a logbook or diary, but
rather consists of a handwritten index created by petitioner.
Moreover, petitioner's testimony regarding the alleged business
purpose of such mileage traveled is uncorroborated by any
testimonial or documentary evidence from Mrs. Whalley or her
employer. We note that the absence of such evidence may lead the
finder of fact to infer that such evidence, if presented at
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