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The parties have stipulated a copy of a purchase agreement
for a 1992 Honda, dated June 13, 1992, at a price of $17,184
(“Unpaid balance * * * $15,884")8, and showing co-purchasers:
petitioner and Norman.
Section 167(a)(1) allows a depreciation deduction with
respect to property used in a trade or business. Section
274(d)(4) requires substantiation of various items with respect
to any deduction for property such as the automobile.
We have already concluded that petitioner failed to prove
that the expenses incident to Aline’s relocation to Florida were
incurred in pursuit of its business. See supra sec. IV.b. We
assume that the mileage described by petitioner for house hunting
in, and relocation to, Florida were incident to Aline’s
relocation there. Any mileage associated with such relocation is
not business mileage. In addition there is no evidence to
support petitioner’s statement that 5,900 miles were attributable
to incidental business activity. Petitioner points to an exhibit
headed “Car Mileage”, which Norman testified was an annual
analysis of business usage of petitioner-owned automobiles made
at the end of each of petitioner’s taxable years. For the 1994
tax year, the entries merely indicate that the automobile was
8 Petitioner has furnished no explanation for its use of
$15,884, rather than the $17,184 purchase price, as the
depreciable cost basis for the automobile.
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