- 12 -
In petitioner’s diary he noted mileage amounts for each of
the days on which he also noted business meals, intending to show
how many business miles he had driven that day. The mileage
amounts that petitioner so noted in his diary total 28,867. In
petitioner’s diary he noted parking and toll amounts for some of
the days on which he also noted business meals, intending to show
business parking and tolls. The parking toll amounts that
petitioner so noted in his diary total $1,101.75.
The Crabtree Dealerships provided various demonstration
vehicles to petitioner for his use during 1987. Petitioner had
exclusive use of these vehicles while the vehicles were in his
possession. Petitioner used these vehicles to commute to and
from work and for other personal purposes. Petitioner did not
incur any repair expenses relating to these vehicles. Petitioner
paid for gasoline, for oil and other maintenance, and $35 per
month rental fee.
Petitioner’s Tax Return
Petitioner’s 1987 tax return was prepared by Morris A.
Levine (hereinafter sometimes referred to as Levine), a C.P.A.,
who signed the tax return as preparer on April 10, 1988. This
tax return was filed timely.
Petitioner’s 1987 tax return was the first tax return Levine
prepared for petitioner. Levine prepared this tax return
primarily from statements made by petitioner and not from
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011