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D. Car and Truck Expenses
Petitioners owned three automobiles in 1993 including a 1992
Lexus, a 1989 Chevrolet, and a 1988 Toyota Camry. The Lexus was
used exclusively, or nearly so, by Mrs. Reynolds. The Chevrolet
was used exclusively for personal transportation. In October of
1994 petitioners traded the Chevrolet, along with cash, for a
Ford van. Petitioner testified that he used the Toyota Camry in
his law practice and to travel to and from his farm and his
various rental properties.
Petitioner did not maintain a log for his business
automobile mileage. During his testimony petitioner presented
documents that were reconstructions of his business mileage. The
reconstructions were created as a result of the examination of
his Federal income tax returns.
As a preliminary step in his reconstructions, petitioner
determined the ratio of business mileage to nonbusiness mileage
for computing depreciation deducted on Schedule C. Included in
total reconstructed business miles is employee business mileage
for which he was compensated by the IRS. Also included in total
business mileage is mileage accumulated commuting to and from his
home and the Cook County courthouse to do research and “back and
forth to the title company” for real estate closings.
Respondent determined that petitioner has not substantiated
his business use of the Toyota Camry.
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