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combination of both, and which of the business expenses were
ordinary, necessary, and otherwise properly deductible under
section 162. Furthermore, a portion of the receipts in this
category are not credible evidence. For example, one receipt for
food was marked as having been incurred for a meeting that
occurred a day earlier, while another receipt for snack food was
marked as having been incurred for a meeting 3 months later.
Petitioner testified that these notations were made at the end of
the year, well after the expenses were incurred. Because the
evidence presented by petitioners is not fully credible, and
because petitioners have failed to provide a sufficient basis to
enable us to conclude that they are entitled to a deduction in
excess of the $4,630 deduction allowed by respondent in the
notice of deficiency, we uphold respondent’s determinations with
respect to these deductions.
The final deductions at issue in this case relate to the car
and truck expenses incurred in connection with Mr. Nitschke’s
musician business. Petitioners presented evidence purporting to
reflect 9,192 miles and, using $.30 per mile, $2,758 in expenses.
Petitioners claimed $2,132 in car and truck expenses on their
return. Because passenger automobiles and any other property
used as a means of transportation are listed property, see sec.
280F(d)(4)(i), (ii), these expenses are subject to the provisions
of section 274(d). Petitioners presented a purported mileage log
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