- 16 - 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 notPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011