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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.
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