Alonzo and Emma J. Bradley - Page 5

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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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