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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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