Vashon C. and Beverly C. Jackson - Page 10




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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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