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use is for the convenience of the employer and is required as a
condition of employment. See sec. 1.274-5T(b)(6) (flush
language), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov.
6, 1985); sec. 1.280F-6T(a)(1), Temporary Income Tax Regs., 49
Fed. Reg. 42713 (Oct. 24, 1984).
Petitioner claimed mileage expense deductions based on his
application of the Federal standard mileage rates to miles he
alleges he drove in business travel. Use of the Federal standard
mileage rates serves only to substantiate the amount of expenses
and not the remaining elements of time and business purpose. See
Rev. Proc. 94-73, 1994-2 C.B. 816.
Petitioner has offered into evidence a computer printout
(the mileage log) with daily listings, for almost every day of
1995, of multiple business trips identified only by abbreviations
under a column captioned “client”.7 Petitioner testified without
elaboration that all of the business miles listed on the mileage
log were “related” to his employment with Compuware. Nowhere
does the record reveal, however, the nature of petitioner’s
purported travel for Compuware, much less the business purpose of
each trip recorded on the mileage log. Having failed to show
that the use of the vehicle or vehicles in question was for the
convenience of Compuware and required as a condition of his
7 The record does not reveal what vehicle or vehicles were
involved in these business trips or who owned the vehicles.
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