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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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