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accorded her a corresponding income tax deduction in the amount
of $888.
Respondent further determined that petitioner was liable for
additions to tax and penalties arising from her 1993 and 1994
returns. For 1993, respondent determined that petitioner owed
$1,373 pursuant to section 6651(a)(1) for failure to file a
timely return, and $1,958 pursuant to section 6662(a) as an
accuracy-related penalty. For 1994, respondent determined that
petitioner owed $1,375 pursuant to section 6662(a) as an
accuracy-related penalty.1
OPINION
Disallowed Deductions
Mileage
The largest deductions claimed by petitioner on her Schedule
C's for the years in issue were $13,160 for mileage driven in
1993 and $13,050 for mileage driven in 1994. Respondent
determined that petitioner failed to substantiate her mileage
deductions as required by section 274(d) and, therefore, limited
the deduction to $4,000 for mileage for each of the years in
issue. Subject to respondent's concessions, we sustain
respondent's determination for 1993 in toto. For 1994, we
sustain respondent's determination only in part.
1 In addition, respondent determined that petitioner owed,
pursuant to sec. 6654, $275 in 1993 and $175 in 1994 for failure
to pay estimated taxes. Because petitioner filed income tax
returns for both years this Court has no jurisdiction and does
not consider these additions to tax. See sec. 6665(b)(2).
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