Michael T. Chappell - Page 16




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          that the car was used by his wife, we do not find that 50 percent           
          of the use of the car was for petitioner’s business for lobbying.           
               Petitioner did not have a log, records, or other                       
          corroboration of his testimony relating to his business use of              
          the Mazda car and truck as required by section 274(d)(4).                   
          Petitioner did not establish the percentages of business use of             
          the car and truck.  See Rutz v. Commissioner, 66 T.C. 879, 883-             
          886 (1976); Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),                
          affd. per curiam 540 F.2d 821 (5th Cir. 1976).  Thus, petitioner            
          may not deduct car and truck expenses for 1994.                             
               At trial, petitioner sought to raise for the first time the            
          issue of his car and truck expenses for 1995.  We ruled that it             
          was then too late to raise that issue.  Even if we had allowed              
          petitioner to raise the issue, he did not show he was entitled to           
          deduct car and truck expenses for 1995.  At trial, he testified             
          that he had a mileage log that showed that he used the truck 100            
          percent for business in 1995.  However, he did not offer a copy             
          of the log into evidence and thus had no records or other                   
          corroboration of his testimony relating to his business use of              
          the Mazda car and truck for 1995.                                           
               3.   Commission and Wage Expenses                                      
               Petitioner deducted commission expenses of $7,980 for 1994             
          and $8,950 for 1995 and wage expenses of $9,500 for 1994 and                
          $9,879 for 1995.  Respondent contends that petitioner may not               






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