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receipt, dated January 30, 2002,10 is from Jiffy Lube and showed
an odometer reading as of that date of 65,189 miles. The second
automobile service receipt, dated December 27, 2002, is from Wal-
Mart Tire & Lube Express and showed an odometer reading as of
that date of 108,190 miles. Thus, the automobile service re-
ceipts showed that the total miles that the Dodge truck was
driven during the period January 30 through December 27, 2002,
was 43,001. In contrast, document one showed that Mr. Shoemaker
claims he drove a total of 72,746 miles for business during 2002,
a difference of almost 30,000 miles.11 We question the accuracy
of document one. We shall not rely on it to establish petition-
ers’ position with respect to any of the expenses for which they
claim deductions for 2002.
The second document (document two) on which petitioners rely
to support their position that they are entitled for their tax-
able year 2002 to deduct job expenses in excess of the amount
allowed by respondent is nothing more than a listing of the total
10The parties stipulated that the first automobile service
receipt is dated June 30, 2002. That stipulation is clearly
contrary to the facts that we have found are established by the
record, and we shall disregard it. See Cal-Maine Foods, Inc. v.
Commissioner, 93 T.C. 181, 195 (1989). The record establishes,
and we have found, that the first automobile service receipt is
dated Jan. 30, 2002.
11The automobile service records cover only Jan. 30 through
Dec. 27, 2002. Assuming arguendo that we were to accept as
reliable the entries for miles that Mr. Shoemaker made in docu-
ment one on days in 2002 not covered by the automobile service
records, such entries total only 6,764 miles.
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