- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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