Michael T. Chappell - Page 15




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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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