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an example the week of March 10, 1997, the calendar reflects
visits to Crivitz, Wisconsin, every day from Monday through
Friday, and that his business mileage for that week was 1,469
miles. However, Crivitz is approximately 32 miles from
petitioner’s home in Oconto Falls. We find it highly unlikely,
at best, that petitioner was able to accumulate such a large
number of miles within and around Crivitz--the round-trip mileage
for the week would be approximately 320 miles, leaving 1,149
miles unexplained.
The 1995 and 1996 calendars contain mileage information
similar to that in the 1997 calendar. Petitioner testified that,
unlike 1997, he kept a daily record of the names of his contacts
in 1995 and 1996. Even if we were to accept this testimony,
however, for reasons similar to those discussed above, we do not
find the weekly business mileage amounts to be credible.
Because petitioners have failed to provide any credible
substantiation to meet the requirements of section 274(d), we
uphold respondent’s disallowance of the claimed car and truck
expenses in each of the years in issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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