Charles and Beatrice M. Reynolds - Page 37




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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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