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of days spent away, (3) destination, and (4) the business purpose
of the travel. Petitioner’s log contains all of this data,
always in the form of the amount, the date of the travel, the
destination (either the University of Michigan library in Ann
Arbor, the Detroit Public Library, or the Purdy Library at Wayne
State23), and the purpose (always recorded as “Research
Beethoven”).
This travel log, however, raises significant issues of
credibility. It records that, from January to May 1997,
petitioner spent every Tuesday and Thursday (with the exception
of May 22, 1997), conducting research at either the Purdy Library
or the Detroit Free Library. This seems to correlate with
petitioner’s testimony regarding his teaching schedule during the
1997 spring semester at Wayne State University. The uniformity
of schedule, however, strongly suggests that petitioner merely
ascribed mileage deductions to his nonteaching days, without
regard to actual events. That petitioner claimed a mileage
deduction for July 4th and Memorial Day, days when many libraries
are closed and most people do not work, also suggests this.
Further, petitioner testified at trial that there were two
23 It is not clear from the record whether these libraries
are “temporary work locations” for purposes of exempting this
travel from commuting expense treatment. See Walker v.
Commissioner, 101 T.C. 537 (1993); Daiz v. Commissioner, T.C.
Memo. 2002-192 (2002); Rev. Rul. 90-23, 1990-1 C.B. 28; Rev. Rul.
94-47, 1994 C.B. 18. Since we have in any event decided to
disallow the mileage expenses, we need not reach this issue.
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