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he traveled to certain job site locations in North Carolina and
Pennsylvania.8 Nor does the record establish the location of the
principal office or place of business of petitioner’s employer
for such periods. Document one also purports to list meal ex-
penses in 2002 of $38 per day for (1) 24 days in each of the
months of April, May, July, August, and October and (2) 30 days
in each of the months of June and September. Petitioner also
relies on another document (document two) to support his position
with respect to the deduction that he is claiming for lodging
expenses. It is not clear from the record when document two was
prepared. Document two purports to list the dates on which
petitioner incurred lodging expenses, the respective names of the
establishments at which such expenses were incurred, and the
amounts of such expenses.
Petitioner concedes that document one was not prepared at or
near the time in 2002 of the expenditures for the use of his
automobile, lodging, meals, and certain unidentified travel
purposes that are at issue. Petitioner failed to establish when
document two was prepared. We find that document one and docu-
ment two do not have the high degree of credibility that would be
present with a record or statement made at or near the time of
the use of petitioner’s automobile and the expenditures for
8In petitioner’s 2002 tax return, which he timely filed,
petitioner indicated that his home address was Keyser, W. Va.
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