§2741

ome . See sec . 6201(d) . We conclude that she had unreported income in the amounts set. forth injour findings . Many of the expenses petitioner claimed were disallowed for lack of substantiation of amount , time, place , and business purpose under section 2741(d ) . Petitioner presented a mileage log that was inconsistent with her testimony and, as she admitted, was not correct; she has now conceded that she is not entitled to deduct mileage for 2006 .1 Some of the transportation expenses and e

31, 1996 52,851 After taking into consideration the agreed adjustments contained in the notice of deficiency for the years ending July 31, 1995 - 2 - and 1996, the issue for decision is whether petitioner’s deductions for expenses incurred in providing officers with nonbusiness flights on a company-owned airplane are limited by section 2741 to the amount reported as imputed income to the recipient officers.

The parties’ controversy raises the question of whether and how section 2741 applies for petitioner’s 1992 and 1993 taxable years.