§2741

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

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.