Raymond Strong - Page 27

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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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