- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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