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The mileage log is supplemented by bank records which show
purchases from the retail establishments or vendors on specific
dates. The date claimed for the business use of the truck in the
mileage log does not correspond in every instance to the date of
the related purchase shown on the bank records. Further, neither
the mileage log nor the bank records show the specific
merchandise purchased from each seller, and it is possible that
petitioners purchased items for their personal consumption as
well as for their farm when they made these excursions using the
truck. It is equally possible that petitioners made additional
trips to acquire farm equipment or supplies but did not actually
make a purchase, so that there might have been additional mileage
costs that do not appear in the mileage log. In any event, Mr.
Stukes testified that the trips shown on the mileage log were
made for the purpose of acquiring farm equipment or supplies, and
we found that testimony credible. Therefore, we find that
petitioners have met the substantiation requirements of section
274 with respect to trips on dates for which there is a
corresponding purchase from a vendor of farm equipment or
supplies. Consequently, we hold that petitioners are entitled to
deduct the cost of using their truck on those occasions.
Of the 44 occasions on which petitioners claim to have used
their truck for the purpose of acquiring farm supplies or
equipment, there are records which confirm farm-related purchases
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Last modified: November 10, 2007