Evelyn J. Glenn - Page 13




                                        - 12 -                                        
           C.  Deductions for Rent (Auto) and Travel                                  
                During the years in issue, petitioner operated only one               
           automobile, which she leased.  On her Schedules C for 1995 and             
           1996, petitioner claimed deductions for rent (auto) in the                 
           amounts of $4,011 and $3,968, respectively.  Petitioner also               
           claimed deductions for “car expenses” in the amounts of $4,682             
           and $5,301, respectively.  In the notice of deficiency,                    
           respondent disallowed the deductions claimed for rent (auto)               
           but, inexplicably, did not adjust the deductions claimed for               
           “car expenses”.                                                            
                Petitioner apparently determined the deductions for rent              
           (auto) by allocating the cost of the lease between business and            
           nonbusiness use of the automobile based on mileage.  In this               
           regard, petitioner claimed on both of her 1995 and 1996                    
           Schedules C that she drove the vehicle a total of 12,000 miles,            
           of which 9,000 miles were for business and the remaining 3,000             
           miles were for “other”.                                                    
                At trial, petitioner introduced no mileage logs or other              
           documentary evidence regarding the use of her automobile.                  
           Petitioner admitted that the vehicle was used for personal                 
           purposes, including commuting.  Regarding the allocation based             
           on mileage, petitioner testified:                                          
                     My accountant did it. * * * I’m not too familiar                 
                with that part of the deduction.                                      







Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011