- 32 - business miles traveled. The use of the standard mileage rate establishes only the amount deemed expended with respect to the business use of a passenger automobile. Id. The taxpayer must still establish the amount (i.e., business mileage), the time, and the business purpose of each use. Id. Petitioner claimed a car and truck deduction of $6,033 on his 2000 Schedule C. Respondent allowed only $780 of the claimed deduction. At trial, petitioner produced little additional documentation. Petitioner was unable to identify which of his two vehicles, the Volkswagen or the Honda, was “Vehicle 1" on his Schedule C. Petitioner explained that he arrived at his total mileage figure of 18,200 by estimation based on his fuel expenditures for taxable year 2000, divided by the average miles per gallon for his two vehicles.19 Petitioner has failed to meet 19Petitioner claims that he spent $1,661.47 on gasoline (87 octane) in 2000. Petitioner determined, from unspecified public records, the average price of gasoline in California for 2000 to be between $1.30 and $1.60 per gallon. Petitioner then determined that the average miles per gallon, combining street and highway, for his two cars was between 30 and 32 miles. Petitioner took his total gas expense, divided it by the average cost of gas per gallon, and then multiplied it by the average miles per gallon of his two cars, which came to approximately 32,000 miles traveled. Petitioner then testified that he assigned approximately 12,000 miles to personal use, and approximately 18,000 to business-related use. Petitioner was required to use a standard mileage rate established by the IRS in lieu of establishing the actual amount of his expenditure. See sec. 1.274-5(j)(2), Income Tax Regs. The business standard mileage rate for the 2000 taxable year was 32.5 cents per mile. Rev. Proc. 99-38, 1999-2 C.B. 525. (continued...)Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: November 10, 2007