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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 Income
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