In Uncategorized on 09/27/2022 at 16:20

While most of their deductions fail for want of documentation, Lori Michelle Patitz and Andrew Robert Moody, T. C. Memo. 2022-99, filed 9/27/22, get whatever automobile mileage for which they were not reimbursed.

Judge Christian N. (“Speedy”) Weiler finds their electronic logbooks pass muster per Reg Section 1.274-5T(c)(2).

“Specifically, Mrs. Patitz testified to handwritten mileage logs she created when she visited clients and would subsequently transfer this information to electronic logbooks. The electronic logbooks Mrs. Patitz provided documented her weekly total mileage, her weekly business mileage, and her weekly commuting mileage. However, she also testified that while the mileage log was written contemporaneously, she inadvertently commingled her business mileage between [employer] and her  [side hustle] activities. During trial Mrs. Patitz conceded that her [side hustle] miles should be excluded, and we agree.

“Mr. Moody also testified that he would transfer the handwritten travel logs that he created to an electronic logbook. Mr. Moody’s electronic logbooks documented the total miles he drove each week and the business purpose of the drive.

“Having observed petitioners’ appearance and demeanor at trial, we find their testimony to be credible with respect to their claimed deductions for vehicle mileage on behalf of their respective employers. Consequently, respondent’s disallowance is overruled, and the Court finds that petitioners are entitled to their claimed deductions for Schedule A vehicle expenses for Mr. Moody’s … vehicle milage [sic] expenses to the extent he was not reimbursed by [employer] and for Mrs. Patitz’s … vehicle expenses to the extent of her [employer] business miles.” T. C. Memo. 2022-99, at p .14.


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