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11. There was no collateral for the advances.
12. Petitioner would not have taken the position with Robert
Randall Co. if the latter had not paid him a substantial amount in
addition to his Form W-2 salary.
13. The value of services petitioner rendered was far in
excess of his Form W-2 salary.
14. Robert Randall Co. could not have hired someone with
petitioner's qualifications for the amount of Form W-2 salary paid
to petitioner.
15. The transferor would have caused the advances to
petitioner to stop if petitioner had stopped providing services.
Based on our determination that the advances were not loans,
but rather represent compensation for services, the advances are
includable in petitioner's income in the year paid.
Issue 2. Automobile Expenses
On petitioners' tax returns for 1989, 1990, and 1991,
petitioners claimed employee business expense deductions with
regard to petitioner's purported business use of an automobile, as
follows:
Year Amount
1989 $4,375
1990 5,200
1991 4,950
Respondent disallowed these deductions.
At trial, petitioner failed to provide any evidence or
substantiation (such as a log or diary) for the claimed expenses
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