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petitioner’s secretary. Petitioner has failed to show any
business necessity for it to spend anything (much less $310) for
two meals for two persons so that the Duquettes, who were
married, lived together, and, as petitioner would have it, worked
together, could discuss the affairs of Norman’s one-man
corporation. See Moss v. Commissioner, 758 F.2d 211, 213 (7th
Cir. 1985), affg. 80 T.C. 1073 (1983); see also Dugan v.
Commissioner, T.C. Memo. 1998-373.
V. Automobile Depreciation
On the 1994 tax return, petitioner deducted depreciation of
$2,550, which it explained as being with respect to an automobile
placed in service on June 17, 1992, costing $15,884, used
100 percent for business, and driven 12,000 miles on business
during the 1994 tax year (the automobile). Respondent disallowed
that deduction, explaining that petitioner had failed to
establish the cost of the automobile, that it was depreciable,
and that it was used in a trade or business.
On brief, petitioner claims:
The company car was driven 12,000 business miles in
FY94 which included a househunting trip from Dallas to
Naples [Florida] in December 1993, a one way trip to
Florida in April 1994 incident to the relocation, and a
trip from Dallas to Phoenix in January 1994 for
consulting. * * * These three trips account for 6,100
of the 12,000 business miles in FY 94. The balance of
the business miles (5,900) is an average of 113 miles
per week for travel to business meetings, post office,
banks, and other incidental business activity.
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