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We do not accept this mileage spreadsheet as reliable
evidence for several reasons. First, we are skeptical of the
number of miles, almost 50,000 in 1 year, that petitioner asserts
were solely business related. This car mileage, we note, is in
addition to miles petitioner flew on his private airplane. We
also find numerous inconsistencies between the spreadsheet and
other evidence before the Court. For example, petitioner
apparently drove to a location on the same day he claimed to have
flown there, and he claimed extensive mileage on days that he was
involved in flight training for his private airplane. Moreover,
petitioner testified that he substantially reconstructed the
mileage spreadsheet during respondent’s examination, which
occurred over 2 years after the year in issue. When petitioner
could not explain certain discrepancies respondent raised,
petitioner responded that he could not remember because the trips
had occurred so long ago. Also, petitioner’s testimony
supporting these expenses is vague and unclear. In petitioner’s
quest to have a paperless office, petitioner produced no
corroborating evidence other than his own self-serving testimony,
which we are not required to accept, and which we do not, in
fact, find to be credible. See Niedringhaus v. Commissioner, 99
T.C. 202, 219 (1992). Accordingly, we do not give any weight to
this mileage spreadsheet.
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