- 5 -5
At trial, petitioner’s counsel said the only other issue
(other than the net operating loss carryover issue) was the
deductibility of auto and travel expenses. Counsel at that point
appeared to be conceding the disallowance of deductions for
entertainment and bookkeeping expenses in the years in question.
No evidence was introduced by petitioner on these two issues. On
brief, petitioner’s counsel erroneously states that bookkeeping
expenses are subject to the rules of section 274, as the
entertainment expenses are.
There is a complete lack of evidence with respect to the
entertainment and bookkeeping expenses, and no valid legal
argument regarding these issues was made by petitioner.
Petitioner has failed to substantiate these deductions. We
sustain respondent as to these two determinations.
There remains the question of petitioner’s disallowed
automobile expense deductions. Petitioner deducted car and truck
expenses of $8,877, $8,420, and $8,315 on his 1993, 1994, and
1995 returns, respectively. The exact amount of the
disallowances of the automobile expense are not part of the
record. At trial, respondent stated that all of the mileage was
allowed except for the commute between the cabin where petitioner
resided and his father’s office. Petitioner did not dispute this
statement.
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