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the weekly expense reports, documents included in the unorganized
packet, related directly to his Schedule C businesses, although
he could not recall to which business the expenses related.
Further, Mr. Nunn testified that although he was reimbursed for
mileage by Tech Solutions, the weekly expense reports submitted
were related to the various Schedules C and not his employment.
The weekly expense reports include a column containing the
mileage driven each day multiplied by 24 cents a mile.3 The
daily amounts were totaled, and the total weekly amount was
entered on a line titled “Total Due Employee”. On each form, Mr.
Nunn checked the box labeled “Mail Check To:” and listed his
mailing address directly under the checked box. Additionally,
Mr. Nunn signed each form. The Court could not understand why
Mr. Nunn would complete each weekly expense report with details
that were inconsistent with his Schedule C record keeping.4 The
Court found Mr. Nunn’s testimony that the weekly expense reports
related to Schedule C businesses and not his employment to be
untruthful.
Petitioners submitted three invoices for computer equipment
3 The standard mileage rate for 1993 was 28 cents per
mile. Rev. Proc. 92-104, 1992-2 C.B. 583.
4 For example, Mr. Nunn could not adequately explain why
he would intentionally check a box and write his mailing address
on each weekly expense form to have a check mailed to himself
that he would have drafted to himself for mileage reimbursement
relating to Schedule C businesses that were operated from his
home address.
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