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The amounts claimed on petitioners’ returns for automobile
business mileage were computed using the standard mileage rate
for the years in issue. See Rev. Proc. 93-51, 1993-2 C.B. 593;
Rev. Proc. 92-104, 1992-2 C.B. 583. Although these revenue
procedures permit taxpayers to use a per-mile estimate of
automobile expenses in lieu of documenting actual expenses,
taxpayers must still prove the actual business miles driven
during the year. See Power v. Commissioner, T.C. Memo. 1990-583.
Dr. Hillman testified that he provided estimates of his annual
business mileage to his accountant by taking the change in the
miles on his odometer for the year, and subtracting an amount
equal to 24 miles per day (i.e., one round trip from his
residence to his medical office) for each of the 4 days per week
that he held office hours. Dr. Hillman did not maintain any
mileage logs or similar documentation of his business use of an
automobile and was unaware at the time of trial of the total
mileage he drove during the years in issue.10
There are a number of problems with petitioners’ attempt to
prove additional business mileage. First, Dr. Hillman’s
testimony reveals that by counting only 4 days per week as
10 Dr. Hillman’s testimony also did not establish that he
utilized a single vehicle exclusively for transportation in
connection with his medical duties, although this position may be
implicit in his testimony. Because we find petitioners’ proof of
additional business miles unavailing for other reasons, we need
not pursue this particular infirmity.
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