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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.
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