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employment, petitioner has failed to substantiate business
purpose as required by section 274.8
In conclusion, petitioner has failed to satisfy the section
274 substantiation requirements for the $8,291 of unreimbursed
employee expenses that he claimed on his 1995 Schedule A.
Accordingly, he is not entitled to the claimed deduction.
To reflect the foregoing and the parties’ concessions,
Decision will be entered
under Rule 155.
8 We also note seeming irregularities involving petitioner’s
mileage log. Petitioner testified that none of the business
miles listed related to his Schedule C business, yet for many of
the business miles, the mileage log lists the client as “PSI”,
which we infer is the same PSI for which JJT performed services.
In addition, for those dates for which personal mileage is
recorded, the mileage log invariably lists either 4, 5, or (more
typically) 6 miles of personal travel for the day, for a total of
796 personal miles, compared with 25,096 total business miles
recorded. Consulting our own experience, it seems improbable
that petitioner’s daily personal use of his vehicle would be so
rigidly fixed and limited, especially in light of the much larger
number of business miles he recorded in 1995.
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