The pilot reported that, during preflight preparations, he estimated the flight time to be about 2 hours and 29 minutes with a total fuel burn of 10.1 gallons. The airplane departed with 12 gallons of fuel. About 2 hours and 25 minutes to the destination airport, the engine quit. He navigated toward a nearby field and made an off-airport landing. He noted that there were tall trees at the beginning of the field and landed long. During the landing, he saw a deep ditch and a house, so he attempted to ground loop the airplane to the left. Both wings impacted trees. The airplane sustained substantial damage to both wings. The pilot reported that there were no preaccident mechanical failures or malfunctions with the airplane that would have precluded normal operation. The pilot reported as a safety recommendation that adding a fuel stop would have prevented the accident. The Federal Aviation Administrator inspector who examined the airplane reported that, the nose tank had evidence of fuel being in it recently, but no fuel remained in the tank (the indicator cork was still wet with fuel). Both the right and left wing tanks were examined and no evidence of fuel remained in either tank. The left fuel tank drain valve had been removed at some point in the past and the opening was covered with green painters' tape. There was no evidence of a fuel spill on the aircraft or the ground around the aircraft.