Daniela Aldea - Page 12




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          activity she conducted.  She further testified that she carried a           
          “1995 business miles log” to all of her Amway activities during             
          1995 and made contemporaneous notes of the activities in the log.           
          The entries in the log and the notations on the calendar                    
          generally indicate the miles driven “to show marketing plan” or             
          to attend “seminar/rally”.  The mileage entries in the log are              
          preceded by the notation “RT”, which petitioner testified stands            
          for round trip but further explained really denotes the one-way             
          mileage to her destinations.  When questioned about the pristine            
          condition of the log and the fact that all entries in the log               
          appear to have been made with the same pen, petitioner explained            
          that she carried the log in a case with a pen.                              
               On the basis of the record as a whole, we find that                    
          petitioner has not substantiated all the required elements of her           
          automobile use, her records are not reliable, and her testimony             
          lacks credibility.                                                          
               Although petitioner’s records purport to provide the dates             
          of business use of her automobile, miles driven for each business           
          use, and evidence of business purpose, petitioner has not                   
          provided the total mileage for all use of her automobile during             
          1995.   See sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50             
          Fed. Reg. 46014, 46016 (Nov. 6, 1985).  Thus, she has not                   
          substantiated all the elements required by the temporary                    








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