Alonzo and Emma J. Bradley - Page 9

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          did not appear at trial or testify to explain this discrepancy.             
          In the absence of any corroborating evidence that Mrs. Bradley              
          used her personal automobiles for business purposes in excess of            
          the mileage reimbursed by GC, we do not find credible the claim             
          that Mrs. Bradley had an additional 10,990 miles of business use            
          in 1992.5  As a result, petitioners fail to meet the requirement            
          of the section 274 regulations that a taxpayer substantiate, with           
          adequate records or sufficiently corroborative evidence, the                
          amount of business use of a passenger automobile.  Accordingly,             
          we sustain respondent's determination disallowing all vehicle               
          expenses claimed by Mrs. Bradley.                                           
               With respect to Mr. Bradley's vehicle expenses, Mr. Bradley            
          also introduced a similar computer-generated spread sheet                   
          purporting to show his own daily business mileage in 1992.  Mr.             
          Bradley's daily entries record mileage ranging from 36 to 54                
          miles, with most entries ranging between 40 and 45 miles for each           
          day of every week that he received overtime pay (i.e., 42 of his            
          50 workweeks in 1992).  Mr. Bradley testified that this daily               
          mileage represented trips between his office at Unisys and                  
          various buildings within the Space Center complex as well as the            
          offices of other subcontractors servicing the SOP Contract.  Mr.            

               5The spread sheet introduced by Mr. Bradley at trial lists             
          mileage of 11,652, which is the business mileage claimed on the             
          return with respect to one of the two vehicles for which Mrs.               
          Bradley claimed business use.  No evidence was offered with                 
          respect to the 1,058 in business miles claimed with respect to              
          the other vehicle.                                                          




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