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various offices.3 Under GC's travel reimbursement procedure,
employees were provided log books in which to record their
business-related travel, and they were required to submit monthly
tallies of their business mileage in order to be reimbursed.
GC's business records for 1992 contain several monthly tallies
with respect to Mrs. Bradley, indicating that she was reimbursed
in the amount of $182.30 for 661.8 miles of business-related
travel in 1992.
Mrs. Bradley claimed a deduction for unreimbursed employee
business expenses in the amount of $5,100 for costs associated
with the use of two personal automobiles. Petitioners calculated
this figure on Form 2106 attached to their return by multiplying
Mrs. Bradley's claimed vehicle expenses (other than depreciation)
for each vehicle, in the amounts of $1,435 and $2,671, by the
claimed business-use percentage for each vehicle, 91 percent and
90 percent, respectively, for products of $1,306 and $2,404 in
vehicle expenses attributable to business use. Petitioners
similarly calculated a $1,390 depreciation expense for one
vehicle based on a claimed business-use percentage of 91 percent.
The business-use percentages used by Mrs. Bradley were calculated
by dividing the claimed business-use mileage of her vehicles for
1992 (11,652 miles and 1,058 miles, respectively) by the claimed
3Our findings regarding GC and its travel reimbursement
policies are based in part on the testimony of Nancy Montgomery,
office manager of GC in 1992. We hereby overrule petitioners'
objection to her testimony.
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