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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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