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purpose of the travel expenses in accordance with those
regulations.” Rev. Proc. 90-15, 1990-1 C.B. at 476.
Petitioners have provided no substantiation for the time,
place, and business purpose for any of the claimed per diem
expenses. We hold, therefore, that petitioners are not entitled
to any deduction for per diem away-from-home expenses for 1993 or
1994.
Issue 7. Section 179 Deduction
Petitioners owned a 1989 Chevrolet that was used exclusively
for personal transportation. In October of 1994, petitioners
traded the Chevrolet, along with cash, for a Ford van. Petitioner
explained in his testimony that he purchased the Ford van to use
as sleeping quarters when he visited his Kentucky farm “rather
than pay $75-$100 a night for a motel”. He also used it to “haul
a tiller, plows, farm implements, this sort of thing” to the farm
in 1994. Petitioner testified that he drove the van a total of
2,234 miles of which 1,866 miles were accumulated from the trip to
Virginia to pick up the “farm stuff” take it to Kentucky, and
return to Illinois.
In their amended petition, petitioners claimed that
respondent had improperly failed to consider their claim for
$12,000 in farm equipment expenses “not properly claimed on
petitioners’ returns as filed.”
During the trial (before respondent had located petitioners’
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