S. Clark Jenkins and Mary P. Jenkins - Page 17

                                         17                                           
               Petitioners have offered no evidence to support their                  
          argument that WSC paid amounts greater than those conceded by               
          respondent.  We will not guess as to any additional amount that             
          WSC could have deducted.  See Lerch v. Commissioner, 877 F.2d               
          624, 628 (7th Cir. 1989), affg. T.C. Memo. 1987-295.                        
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          
































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