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provide counseling and other services to the homeless for a fee.
Petitioner attempted to raise money through mailings and
meetings.
As it turned out, petitioner was unable to raise the money,
and his idea never materialized. Petitioner worked an
unspecified number of Saturdays and Sundays, but he did not
receive compensation for his services.
Petitioner used his car to commute from home to his various
places of employment and other locations. Petitioner submitted a
handwritten mileage log reflecting the dates he drove, where he
drove, and the exact odometer reading at the beginning of each
trip. Petitioner recompiled this log around the time he was
audited, using a spiral calendar and a small notebook in which he
had contemporaneously logged his mileage information. Petitioner
submitted neither the calendar nor the notebook into evidence.
The log shows that petitioner traveled to his Navy chaplain’s
duties, to bookstores, to church meetings, to his INS office, to
the library, and to PFS’s office. The log indicates that
petitioner drove 20,617 miles during 1993, of which he asserts
that 12,157 (about 59 percent) were business use miles.
Petitioner submitted a “Library List” and photographs that
reflect a sample of the 6,000 books that he purportedly has in
his personal library. These books, purchased over the past 20
years, are on the topics of philosophy, theology, religion, and
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