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incurred in going from one workplace to another are generally
treated as trade or business expenses deductible under sec.
162(a). E.g., Steinhort v. Commissioner, 335 F.2d 496, 504-505
(5th Cir. 1964), affg. and remanding T.C. Memo 1962-233; Dancer
v. Commissioner, 73 T.C. 1103 (1980).
The claimed business use of the vehicles that the Crabtree
Dealerships leased to petitioner is for business meetings (such
as with bank employees) and for demonstrations to customers and
potential customers. Although we are satisfied that petitioner
did have business meals in 1987, our efforts to determine the
amount of business usage of petitioner’s vehicles and the amount
of petitioner’s vehicle-related expenses have largely foundered
on the inadequate record herein and on the contradictions in
petitioner’s contentions.
For reasons explained supra, we have concluded that
petitioner’s diary and stubs are unreliable. In addition, there
is no evidence in the record as to the locations of many of the
restaurants named in the diary and on the stubs, and no evidence
as to locations of any nonmeal business meetings, so we could not
check on the mileage figures petitioner wrote in his diary.
Although we are satisfied that petitioner incurred some vehicle-
related expenses, we do not have any reliable evidence as to the
$5,111 he claims to have spent on the vehicles. Supra table 3.
Also, we have no satisfactory explanation of why petitioner
claims that his “Average daily round trip commuting distance” is
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