- 8 -
materials, including brochures. Petitioner also testified with
respect to additional advertising expenses. We found
petitioner's testimony credible. Therefore, we conclude that
petitioner is entitled to deduct $830.16 in advertising expenses.
Cohan v. Commissioner, supra.
3. Car and Truck
Petitioner claimed automobile expenses in the amount of
$2,600.24. Petitioner estimated the business use of her
automobile to be approximately 70 percent of the total use. We
accept petitioner's credible testimony in this regard.
Petitioner calculated the amount of $2,600.24 on the basis of her
actual expenses rather than mileage expenses in 1994. A taxpayer
must establish his out-of-pocket expenses attributable to the
business use of his automobile, such as gasoline, oil, and
repairs. Sec. 1.162-1(a), Income Tax Regs. Automobile expenses
are deductible if the automobile is used in connection with a
trade or business. Sec. 1.162-1(a), Income Tax Regs. Petitioner
testified that her activities with APIA required much local
travel, and she explained the nature of such activities.
A large portion of the gasoline expenditures was in cash.
Petitioner also produced some credit card statements in support
of her testimony to the extent gas purchases were made with
credit. Petitioner produced credit card statements, invoices,
and receipts with respect to the repairs performed on her car in
1994. Ms. Gaman prepared an attachment for petitioner's 1994
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