Barry S. and Yvonne C. Hillman - Page 30

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          effectively claiming that he drove at least approximately 70 and             
          82 business miles per day on average in 1993 and 1994,                       
          respectively.12  According to Dr. Hillman’s testimony, his                   
          residence, medical offices, and the five hospitals at which he               
          worked were all located in the Columbus, Ohio, area.  There is no            
          evidence of the distance between Dr. Hillman’s office and the                
          hospitals, between the hospitals themselves, or between Dr.                  
          Hillman’s residence and four of the hospitals.  Without such                 
          evidence there is no corroboration for Dr. Hillman’s testimony,              
          and we are not required to accept such self-serving testimony.               
               On this record, petitioners have failed to prove that the               
          mileage amounts allowable in computing the section 162(a)                    
          deduction with respect to Dr. Hillman’s medical practice are any             
          greater than the amounts determined by respondent.  See Russell              
          v. Commissioner, T.C. Memo. 1989-326; Joint Implant Surgeons,                
          Inc. v. Commissioner, T.C. Memo. 1988-558.                                   

               12 Without accounting for holidays or vacations, a 6-day                
          work week, as claimed by Dr. Hillman, generally results in 312               
          work days per year.                                                          
               Dr. Hillman claimed 24,368 business miles in 1993.                      
          Subtracting the additional 2 days per week of commuting miles--              
          namely, 2,492 miles annually--leaves 21,876 business miles over              
          312 days, or 70.1 business miles per day on average in 1993.                 
               Dr. Hillman claimed 28,027 business miles in 1994.                      
          Subtracting an additional 2,492 commuting miles leaves 25,535                
          business miles over 312 days, or 81.8 business miles per day on              
          average in 1994.                                                             
               If one assumes that Dr. Hillman took any holidays or                    
          vacation days during the year, the average number of business                
          miles per work day goes higher.                                              

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