- 14 - was driven a total of 48,490 miles between January 16, 1997, the first day of her first job assignment that year, and December 31, 1997. Petitioner submitted two vehicle maintenance receipts that showed the odometer readings on October 5, 1997, and January 13, 1998. The odometer readings on the receipts were consistent with petitioner’s log. Although the log apparently accurately reflects petitioner’s total mileage for the year, the record does not clearly show what portion of the total miles was driven for business purposes. The mileage in petitioner’s log was not recorded precisely. For example, the mileage for any given day was generally identical to the mileage from the day before, and her daily mileage was always rounded to the nearest multiple of ten. Petitioner testified that she often estimated the mileage from the amount of time she spent driving. For example, she admitted that it was not unusual for her to simply equate one hour of driving with a distance of 60 miles. Although revenue procedures permit taxpayers to use a per- mile estimate of automobile expenses in lieu of documenting actual expenses, taxpayers must still prove the actual business miles driven during the year. See Power v. Commissioner, T.C. Memo. 1990-583. The level of detail required to substantiate the number of business miles driven may vary depending upon the facts and circumstances. Sec. 1.274-5T(c)(2)(ii)(C), Temporary IncomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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