- 8 - trips were taken for employment-related purposes. On those occasions when Carolyn R. Ellis accompanied petitioner, he explained that she did so as his “advisor”. We think it more likely than not that the trips were taken primarily for personal purposes; that is, so that one or both petitioners could visit their children. The expenses of those trips constitute nondeductible personal or family expenses. See sec. 262. The car expense deduction is allowable only if petitioner maintained substantiating records. See secs. 274(d), 280F. Assuming, without finding, that petitioner’s records otherwise satisfy the requirements of section 274(d) and the regulations promulgated thereunder, we reject them as unreliable. Petitioner’s records indicate that he drove to the offices of one prospective employer numerous times during 1995; the prospective employer claims no contacts were made. Similarly, other prospective employers could not confirm petitioner’s claims to have contacted them during the years in issue. Rejecting petitioner’s substantiating records, in effect, operates to deny any deduction for car expenses. We could continue to discuss other deductions claimed on the Schedules C, but given our conclusion that the expenses are not deductible as trade or business expenses in the first place, we see little purpose in doing so. Respondent’s adjustmentsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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