- 27 - 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” isPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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