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During taxable year 2000, petitioner was employed full-time
as a consultant for Arthur Anderson, LLP. As part of his
employment with Arthur Anderson, LLP, petitioner traveled to
various Arthur Anderson, LLP offices.
Also, during the year in issue, petitioner was a self-
employed attorney/accountant. Petitioner assisted clients with
drafting documents for different types of transactions and
provided tax return preparation, valuation, and assorted legal
and paralegal accounting and tax consulting services
(petitioner’s business).
Petitioner drove about 13,980 business-related miles of
which approximately 4,300 miles were for travel to the Chapman
University Law School Library in the city of Orange in Orange
County, California. As previously stated, petitioner is an
alumnus of Southwestern University School of Law. The
Southwestern University School of Law Library is located
approximately 5 miles from petitioner’s home.
In 1995, petitioner and Donna Lynn Wold (Ms. Wold) entered
into an oral agreement, whereby Ms. Wold purchased a 1991 BMW
525i and then agreed to sell the vehicle to petitioner after he
paid her a downpayment and made 60 monthly payments.
As a result of problems stemming from this oral agreement,
petitioner filed a complaint against Ms. Wold in the Superior
Court of the State of California for the County of Orange on
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