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Our review of the record reveals the following:
(a) During 1987, 1988, and 1989, petitioner leased two cars
for business purposes--a 1988 Toyota Camry from Wilkens Toyota
for general office use (driven by the process server, law clerk,
courier, and petitioner) and a 1987 Toyota Tercel from GE Credit
Auto Leasing for her secretary’s use. Petitioner had another car
for her personal use.
(b) During 1990, petitioner leased three cars for business
purposes--a Toyota Tercel, a Toyota Camry, and a Hyundai that was
leased in March 1990.
(c) For 1987, petitioner documented, and respondent concedes
the deductibility of, car expenses of $2,426.15 (Ex. 38-R, lines
283-297), $5,099.07 (Ex. 38-R, lines 1005-1015), and $1,231 (Ex.
38-R, lines 809-812; SSR dated 9/10/99), for a total amount
documented of $8,756.22.
(d) For 1988, petitioner documented, and respondent concedes
the deductibility of, car expenses of $7,582.50 (Ex. 39-R, lines
355-382; SSR dated 9/10/99), $478.90 (Ex. 39-R, lines 577-595),
and $439.82 (Ex. 39-R, lines 1744-1764; SSR dated 9/10/99), for a
total amount documented of $8,501.22.
(e) For 1989, petitioner documented, and respondent concedes
the deductibility of, car expenses of $4,409.13 (Ex. 40-R, lines
223-239; SSR dated 9/10/99), $1,236.30 (Ex. 40-R, lines 402-428),
$748.78 (Ex. 40-R, lines 1533-1538, 1540-1559; SSR 9/10/99), and
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