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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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