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Corolla that she used for all her transportation needs, including
business travel, commuting to work, and personal use. Petitioner
did not maintain a mileage log or diary of miles driven in 1997.
Petitioner timely filed her 1997 Federal income tax return.
Petitioner reported on Schedule C, attached to her 1997 return,
gross income from Boyd PC Consulting of $7,520. Petitioner
claimed the following Schedule C expenses:
Expense Claimed
Advertising $1,490
Car and truck 2,347
Depreciation 205
Repairs/maintenance 1,200
Travel, meals & enter- 2,620
tainment
Other 4,000
Total $11,862
On the Vehicle Expense Worksheet, attached to her 1997 return,
petitioner reported 12,500 total miles driven in 1997. Of that
amount, 7,450 miles were reported to be used for business
purposes. Petitioner claimed a car and truck expense of $2,347
based on the purported 7,450 business miles multiplied by the
standard mileage rate of $0.315 per mile.
In the notice of deficiency respondent disallowed the above
Schedule C expense deductions in their entirety because
petitioner failed to show that each claimed deduction was an
ordinary and necessary business expense, or, in the alternative,
because petitioner failed to substantiate that she paid or
incurred the expense for which the deduction was claimed.
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Last modified: May 25, 2011