- 12 - 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 temporaryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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