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underlying books or records. In particular, petitioner did not
give petitioner’s diary to Levine.
On his 1987 tax return, petitioner claimed the deductions
shown in table 2.
Table 2
Form 2106
Meals and entertainment $62,500
Less: 20 percent 112,500 $50,000
Vehicle expenses 4,016
Parking fees, tolls, and local trans. 900
Other business expenses 840
Total Form 2106 $55,756
Schedule A
Form 2106 $55,756
Tax preparation fees 250
56,006
Less: 2 percent A.G.I. 23,350
Net miscellaneous deductions 52,656
1 Petitioner acknowledges the limitation, and showed it on his
tax return. Sec. 274(n).
2 Petitioner acknowledges the limitation, and showed it on his
tax return. Sec. 67. Both sides agree that $3,350 is the
correct amount.
On the Form 2106 of his 1987 tax return, petitioner arrived
at the $4,016 vehicle expenses amount shown in table 2, by the
route described in table 3.
Table 3
Total mileage vehicle used 35,000 mi.
Business use 27,500 mi.
Percent of business use 78.571
“Average daily round trip commuting distance” 10 mi.1
Total commuting 2,500 mi.2
Other personal mileage 5,000 mi.
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