- 33 - 1991 and 498 miles per day in 1992.4 At an average rate of 60 miles per hour, Mr. Black would have had to drive between 7 and 8 hours per day, 7 days per week,5 not including time spent stopped for gas or meals, or meeting with clients. At trial, both petitioners testified that Mr. Black “loved to drive”. Petitioners argue that Mr. Black’s business was just starting up and client contact was very important. However, petitioners failed to identify even one instance of any business- related travel for either year in issue by destination or name of client. Additionally, the original travel log is now missing and is not part of the record. Mr. Black may have traveled for business purposes. However, we are convinced that the deductions for travel claimed on the 1991 and 1992 joint returns are grossly overstated. We find that such overstatements are indicative of Mr. Black’s fraudulent intent to avoid taxes. Petitioner is an intelligent and well-educated businessman. We find that he had a basic comprehension of Federal tax matters and he understood that individuals must report their gross income and can only claim deductions for amounts actually paid in the ordinary and necessary course of business, and not for personal expenditures. 4156,669/365 = 429.23; 181,692/365 = 497.79 5429/60 = 7.15; 498/60 = 8.3Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: March 27, 2008