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conducted with the primary purpose of making a profit.
Petitioner did not report on his 1994 or 1995 returns that he
received $200 annually from lobbying; even if he had, this small
amount of income would not establish that the lobbying activity
was a trade or business in 1994 or 1995.
2. Car and Truck Expenses
A taxpayer may not deduct car and truck expenses unless he
or she substantiates by adequate records or sufficient evidence
corroborating the taxpayer’s own statement the amount, time,
place, and business purpose of the car and truck use. See sec.
274(d)(4).
Petitioner testified and contends that, in 1994, he used the
1994 Mazda truck solely for his tax preparation business, for
example, to haul desks and file cabinets between the office at
his home and the one-room schoolhouse, and that 50 percent of the
use of a 1993 Mazda 929 was for his lobbying business.
Petitioner’s claim that he used the truck 100 percent for
business is implausible. We believe he used the truck for
personal purposes because his wife drove the Mazda 929 and he
owned no other cars. He offered no evidence of the number or
length of trips or the total mileage of the truck for 1994.
Petitioner claims that he used the Mazda 929 in his lobbying
activity; however, as discussed above, he has not shown that the
lobbying activity was a trade or business. In view of the fact
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