- 3 - warranty would be issued. A typical job lasted 3 months and required petitioner to travel to the jobsite five times or more. During 2000, petitioner’s clients were located in Texas and Louisiana. Armko did not reimburse petitioner for expenses related to his sales activities. Petitioner claimed $l5,7411 of automobile expenses2 as unreimbursed employee business expenses for 2000. He testified that he daily maintained a mileage log by recording the odometer reading for each sales call on the day that he made the sales call, then transferred this information into a spreadsheet on his personal computer because, as he testified, he wanted to have a “more efficient paperless office.” Petitioner maintained no other paper records for the business use of his automobile. The mileage log contained entries that were inconsistent with and in fact contradicted other evidence before the Court.3 For example, there were numerous entries on the same day on both the flight log and the mileage log that showed times and distances traveled that could not have taken place on the same day. Petitioner 1All dollar amounts are rounded to the nearest dollar. 2Petitioner claimed 48,434 miles, at the standard mileage rate of 32.5 cents per mile, as business purpose miles on Form 2106, Employee Business Expenses, for 2000. The standard mileage rate for 2000 is set forth in Rev. Proc. 99-38, 1999-2 C.B. 525. 3Petitioner submitted a flight log to substantiate expenses he claimed involving his 1960 Cessna 182-C airplane. The parties settled the Cessna airplane expense issue in the stipulation of settled issues. Accordingly, we consider the flight log only as it relates to petitioner’s automobile expenses.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011