Kenneth G. Schladweiler - Page 4




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          for each year.  Respondent also acknowledges that the allowance             
          for depreciation must be recomputed due to the allowance of                 
          additional repair expenses that respondent previously classified            
          as capital expenses.                                                        
          Discussion                                                                  
               We address each of the remaining disputed adjustments below.           
               Car and Truck Expenses                                                 
               On his Federal income tax returns for the years at issue,              
          petitioner claimed the following with respect to car and truck              
          expenses:                                                                   
               1992 - Petitioner claimed that he drove a pickup truck 67              
          percent for business during 1992.  He also claimed that he drove            
          the pickup 22,194 miles, of which 14,892 were business miles, and           
          7,302 were personal (noncommuting) miles.  On his Schedule C, he            
          claimed car and truck expenses of $4,170.  The deduction was                
          calculated using the standard mileage rate for 1992.                        
               1993 - Petitioner claimed that he drove an automobile 74.4             
          percent for business during 1993.  He also claimed that he drove            
          the car 24,522 miles in 1993, of which 18,245 were business miles           
          and 6,277 were personal (noncommuting) miles.  On his Schedule C,           
          he claimed car and truck expenses of $5,109.  The deduction was             
          calculated using the standard mileage rate for 1993.                        
               At trial, petitioner testified that he used a 1979 Ford                
          pickup truck and a 1979 Mercury Cougar for his business travel.             






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