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with that deduction, petitioner stated in Part IV, Information on
Your Vehicle, of his 1994 Schedule C that he placed his vehicle
in service for business purposes on April 15, 1994, and that he
subsequently drove the vehicle 21,500 miles, of which 15,500 were
for business, 3,000 were for commuting, and 3,000 were for
“other”. At trial, petitioner contended that he is entitled to a
larger deduction for car and truck expenses in the total amount
of $9,981.01, as reflected on an exhibit entitled “Summary of
1994 Auto Expenses”. Petitioner alleged that he drove 17,575
miles for business purposes and that the business use of his
vehicle was summarized on an exhibit entitled “1994 Daily Log”.
Although petitioner admits that the entries in the daily log were
not made contemporaneously, he contends that the daily log was
reconstructed using contemporaneous notes that he filled out each
time he traveled on business and then threw in a box. Petitioner
did not introduce into evidence the notes he claims he kept in
the box.
Respondent conceded on brief that petitioner used his
automobile for business purposes and that he has documented
business mileage of 336 miles. Respondent also conceded that
petitioner substantiated the following automobile expenses:
Lease payments $4,521
Insurance and lic. 2,107
Oil Max 43
Total $6,671
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