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business hours, to reach the claimed business mileage. Moreover,
Mr. Bradley claimed a relatively constant level of mileage for
each workday of an overtime week, whether his overtime hours for
the week were modest (e.g., 8 hours) or extensive (e.g., 31
hours).6 Given these circumstances, we do not find Mr. Bradley's
log of business use credible. We conclude that the claimed
business miles of 9,976 in 1992 are inflated. Because we find
unreliable the evidence offered by Mr. Bradley of his business
use, 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 Mr. Bradley.
Miscellaneous Employee Business Expenses
Respondent also disallowed the deduction for miscellaneous
business expenses attributable to Mr. Bradley's employment in the
amount of $189. Since petitioners offered no evidence with
respect to this amount, we sustain respondent's determination.7
6For the week ended Jan. 17, 1992, Mr. Bradley worked 8.5
hours of overtime and logged between 41-43 miles for each day
January 13th through January 17th. For the week ended Jan. 24,
1992, Mr. Bradley worked 31 hours of overtime and logged between
41-44 miles for each day January 20th through January 24th.
7Respondent conceded the $677 in miscellaneous employee
business expenses claimed with respect to Mrs. Bradley's
employment.
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