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the rates are deductible as unreimbursed employee business
expenses. Petitioner husband's travel vouchers show that he was
generally reimbursed at the rate of 24 cents per mile in 1990 and
early 1991 and at the rate of 25 cents per mile in late 1991 and
1992 and, on limited occasions, at 9-1/2 cents per mile. It is
not clear from the travel vouchers or petitioner husband's
testimony as to why or for which miles he was reimbursed at a
lesser rate of 9-1/2 cents per mile.
Based on the travel vouchers and petitioner husband's
testimony, we find that petitioners have substantiated the number
of miles which they claimed petitioner husband used his
automobile in connection with his employment as an auditor. See
sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg.
46016 (Nov. 6, 1985). After accounting for the differences
between the standard mileage rates and the rates at which he was
generally reimbursed, we find that petitioners have established
that petitioner husband's allowable expenses for the use of his
car during 1990, 1991, and 1992 exceeded his advances and
reimbursements for such use by $642, $1,388, and $1,248,
respectively.
4(...continued)
and 1992 were 26 cents, 27-1/2 cents, and 28 cents, respectively.
See Rev. Proc. 89-66, sec. 4.01, 1989-2 C.B. 792, 793; Rev. Proc.
90-59, sec. 4.01, 1990-2 C.B. 644, 645; Rev. Proc. 91-67, sec.
5.01, 1991-2 C.B. 887, 888.
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