Albert William Dehr, III and Yoeng Yoep Dehr - Page 10

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          and necessary expenses for local transportation, and rules were             
          prescribed for the year 1994.  See Rev. Proc. 93-51, 1993-2 C.B.            
          593.                                                                        
              As part of their attempt to meet the substantiation                    
          requirements, petitioners provided the Court with a handwritten             
          document that petitioner testified is a record of starting and              
          ending mileage for each of the vehicles, the pickup truck and the           
          Lincoln.  The document indicates the total miles driven for the             
          year for each vehicle:  34,748 miles for the truck and 15,089               
          miles for the Lincoln.4                                                     
                    The Lincoln                                                       
               Of the total mileage for the Lincoln, petitioners claimed              
          7,289 as business miles on a statement attached to their return.            
          On the same statement petitioners indicated that they possessed             
          written evidence to support the claimed business use.  No such              
          written evidence was offered at trial.  Petitioner instead                  
          testified that to determine business mileage he took the total              
          mileage of 15,089 and reduced it by 7,800 for his wife's personal           
          use mileage.  When asked how he determined personal use mileage,            
          petitioner replied:  "That was a guesstimate by what [my wife]              
          was using to drive around".  Petitioner's use of a "guesstimate"            
          of personal mileage means that the number of business miles                 

               4Respondent noted a relevance objection to petitioners'                
          stipulated computation.  We disagree and find the document to be            
          relevant.                                                                   




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