- 11 - we find that petitioner made trips to Virginia City on an average of three times per week during 20 weeks during the year, for a total of 4,800 miles. At the standard business mileage rate of 28 cents per mile in effect for 1992 under Rev. Proc. 91-67, supra, petitioner is entitled to a mileage allowance deduction for local travel of $22.40 per day, or a total of $1,344. We sustain the balance of respondent's disallowance of petitioner's claimed car and truck expense deduction. 4. Legal and Professional Expenses of $3,342 Petitioner testified that "primarily" the $3,342 was paid for production costs and that a "small amount" was for legal expenses. Petitioner testified that the production costs included both amounts paid to the production assistant in Virginia City and amounts paid to sound engineers. Petitioner testified that he worked with the production assistant to determine a budget and how much of the fee petitioner would keep and how much the production assistant would keep. However, petitioner presented no invoices or other documentation showing how the services of the production assistant were billed and paid for. Although petitioner testified that he reported the gross amounts paid under the contracts, it is not clear--indeed it seems unlikely--that the production assistant's share was part of the gross income reported by petitioner. We do not believe thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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