Albert William Dehr, III and Yoeng Yoep Dehr - Page 14

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          of travel denoted as "FUDD", or payroll travel, or for claimed              
          parking fees, tolls, property taxes, and interest.  Sec. 1.274-             
          5T(c)(3)(iii), Temporary Income Tax Regs., 50 Fed. Reg. 46016               
          (Nov. 6, 1985).                                                             
               We find, however, that petitioners, under the facts and                
          circumstances of this case, have provided an adequate record of             
          substantiation for the use of their truck for 162 round-trips of            
          162 miles each, or 26,244 miles of business transportation, from            
          petitioner's home office to and from Ro-Tile in 1994.                       
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               

























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