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petitioner deducted each year for that expense. Moreover, some
of the receipts suggest that the expense incurred should not be
deductible at all. For example, petitioner testified that the
only car he used to travel to the locations of the various audits
he conducted during the years in issue was a personally owned
Cadillac, but several repair bills refer to a Bonneville. Also,
numerous receipts relate to the purchase of gasoline. The
quantities of gasoline purchased suggest that the tank of the car
was being filled. In some instances the receipts were produced
at the same filling station on the same day, sometimes within
minutes of each other.
Petitioner contends that he is unable to substantiate all
his Schedule C deductions because many of his receipts were
destroyed in a flood in 1995. Although petitioner established
that his residence suffered flood damages during that year, he
has not made any attempt to reasonably reconstruct those records
for 1993 or 1994. Based upon what evidence was presented, we
think it highly unlikely that even if petitioner reconstructed
his traveling expenses, the total of such expenses would exceed
the amount of the reimbursements that he received from his
employer during the years in issue.
Neither petitioner’s travel log nor the receipts introduced
into evidence during the trial constitute adequate substantiation
for the traveling expenses deducted on the Schedule C each year
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