- 4 -
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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