Kevin J. and Crystal A. Shoemaker - Page 13

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         parking fees and tolls that petitioners claim he paid.8                      
              The total amount of miles for 2002 of 72,746 that petition-             
         ers claim Mr. Shoemaker drove for business, as reflected in                  
         document one,9 is inconsistent with and contradicted by the total            
         amount of miles for 2002 of 43,001 that petitioners claim Mr.                
         Shoemaker drove for business, as reflected in certain other                  
         evidence.  Such other evidence consists of two receipts for                  
         service (automobile service receipts) that petitioners introduced            
         into the record as evidence of such total amount of miles.  The              
         automobile service receipts are for service during 2002 on a                 
         black 2001 Dodge Dakota truck (Dodge truck) that petitioners                 
         claim Mr. Shoemaker drove during 2002 between petitioners’ resi-             
         dence and his job site locations.  The first automobile service              



               8Certain of the claimed monthly totals that Mr. Shoemaker              
          entered in document one are not accurate.  For example, for                 
          February 2002, Mr. Shoemaker made entries showing the total                 
          number of days worked, the total miles that petitioners claim he            
          drove between petitioners’ residence and the job site locations             
          at which petitioners claim he worked, and the total parking fees            
          and tolls that petitioners claim he paid as 27 days, 6,156 miles,           
          and $85.90.  However, the actual respective monthly totals of the           
          daily amounts that Mr. Shoemaker entered in document one for                
          February 2002 for such items are 24 days, 5,472 miles, and $76.             
               9We have used as the total miles for 2002 that petitioners             
          claim Mr. Shoemaker drove for business, as reflected in document            
          one (i.e., 72,746), the total of the daily entries that Mr.                 
          Shoemaker made in document one for the respective miles that                
          petitioners claim Mr. Shoemaker drove each month during 2002                
          between petitioners’ residence and the respective job site                  
          locations at which petitioners claim Mr. Shoemaker worked.  See             
          supra note 8.                                                               




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