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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 adjustments
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