Teresita T. Daiz - Page 15




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          Tax Regs., 50 Fed. Reg. 46018 (Nov. 6, 1985).  Where a taxpayer             
          makes regular trips to a certain location, she may satisfy the              
          adequate record requirement by recording the total number of                
          miles driven during the year, the length of the route once, and             
          the date of each trip at or near the time of the trips.  Id.                
               In the present case petitioner has substantiated the number            
          of round trips she made for business purposes between her                   
          residence and her temporary work sites and the distance of each             
          round trip.  We have found that in addition to the undisputed               
          5,040 business miles that petitioner drove to Bakersfield, she              
          also drove 24,598 miles to various temporary work sites during              
          1997.  Since petitioner has satisfied the adequate record                   
          requirement for this mileage and therefore substantiated this               
          business expenditure, we hold that petitioner is entitled to the            
          claimed deduction to the extent of the substantiated mileage                
          (24,598 miles plus the undisputed 5,040 miles) at the appropriate           
          rate for 1997.                                                              
               If a taxpayer’s otherwise deductible traveling expenses are            
          reimbursed by her employer, the taxpayer is entitled to a                   
          deduction only for the amounts in excess of the reimbursements.             
          See Jackson v. Commissioner, T.C. Memo. 1999-226; sec. 1.162-               
          17(b)(3), Income Tax Regs.; sec. 1.274-5T(f)(2)(iii), Temporary             
          Income Tax Regs., 50 Fed. Reg. 46028 (Nov. 6, 1985).                        
               Petitioner admitted that her employer reimbursed her $525              
          for her vehicle expenses in 1997.  Petitioner did not report the            






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