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promulgated thereunder in each taxable year; a taxpayer’s method
of substantiation which does not meet the statutory and
regulatory requirements does not entitle a taxpayer to a
deduction, even if respondent previously accepted similar
substantiation. See id.; Rose v. Commissioner, 55 T.C. 28, 32
(1970).
Petitioner provided appointment calendars for each of the
years in issue as purported substantiation of the mileage
expenses. The 1997 calendar contains names of cities written at
the beginning of most weekdays which are meant to record the
cities visited by petitioner in connection with his business.
The calendar also contains names of individuals whom he
purportedly visited while on some of these trips. However, these
names were added by petitioner during the audit of petitioners’
return. Weekly totals of business miles were recorded in the
calendar, but we do not accept these figures as credible evidence
of the mileage petitioner actually incurred. How petitioner
derived these numbers was not explained at trial; there is no
evidence that a log was maintained allocating business and
personal mileage on the vehicle. Most importantly, the amounts
are not credible. In 1997, petitioners reported 64,638 business
miles. The calendar reflects that petitioner worked 247 days in
1997, which would imply that petitioner drove the automobile an
average of 262 miles each business day. Furthermore, taking as
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