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situations requiring transportation expenses for which Stores
would not have reimbursed him. He alleged that his
transportation expense deduction was related to the unscheduled
“emergency” trips.
Petitioner’s evidence on the issue consisted of Stores’
check stubs showing reimbursements to him of $1,550, presumably
for scheduled trips, and a computer-generated monthly log titled
“Mileage - Tax Year 2002”, purporting to show cumulative monthly
mileage to “county locations” in 2002. It is interesting to note
that the same three counties, Orange, “LA”, and San Diego, as
well as “miscellaneous mileage” are listed every month. The
total mileage traveled each month is also fairly consistent.
According to petitioner’s evidence, his “emergency” unscheduled
transportation expenses were a startling 623 percent of his
reimbursed expenses for scheduled trips.
Further complicating matters for petitioner, the Court is
unable to determine from his evidence which of his trips were
reimbursed and which were not because his evidence does not meet
the standard of section 274(d). Respondent’s determination on
this issue is sustained.
Other Expenses
Petitioner claimed $1,245 of “other” business expenses. The
Court presumes that the Verizon Wireless cell phone bills and
miscellaneous receipts offered by petitioner were submitted as
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Last modified: May 25, 2011