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testimony at trial. Petitioners’ car and truck expenses were not
properly substantiated under the cited legal authority.
On the other Schedules C of the tax returns for 1994 and
1995, petitioners deducted car and truck expenses, supplies,
insurance, office expenses, and utilities for an Amway activity.
Ms. Rhodes was also responsible for all record keeping for this
activity. Petitioners deducted car and truck expenses of
$1,672.43 and $6,830.70, respectively, for 1994 and 1995. The
extent of the records substantiating the mileage reported for
Amway trips was a total mileage number listed at the top of
monthly calendars. On Ms. Rhodes’s monthly calendars for 1995,
she listed 27,135 miles driven in support of the Amway activity
but only reported 22,769 miles on their 1995 return. Similarly,
Ms. Rhodes’s monthly calendars for 1994 listed total mileage of
10,239.7; however, only 5,767.4 miles for travel was reported on
their 1994 return. Ms. Rhodes offered no explanation for the
discrepancies at trial. In addition, Ms. Rhodes’s records for
the Amway activity were as vague as the records for Keepsake.
When Ms. Rhodes went out to recruit distributors, she would
simply write “Prospecting Day” and a list of first names with
mileage amounts beside them. She could offer up no more
specifics on people or locations; however, Ms. Rhodes claimed she
had turned over a log book containing specific records to the
examiner. The examiner testified that a log book was never
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