Linda Klyce - Page 19




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          and equipment expense deduction for any amount for 1991.  The               
          Court sustains respondent's disallowance of this expense.                   
               On her 1992 amended return, petitioner claimed $4,290 for              
          food expenses that was disallowed by respondent.  In the                    
          stipulation, respondent conceded that petitioner was entitled to            
          a $922 food expense deduction in connection with Sweets 'N'                 
          Things for 1992.  Petitioner did not present evidence to satisfy            
          the Court that she is entitled to a food expense deduction                  
          greater than the amount conceded by respondent.  The Court holds            
          that petitioner is not entitled to a deduction in excess of the             
          amount conceded by respondent.                                              
               The next item is whether petitioner is entitled to travel              
          expense deductions for 1991, 1992, and 1993 in connection with              
          Special O.  Respondent disallowed travel expenses claimed by                
          Special O in the amounts of $740.81, $2,497, and $1,529 for 1991,           
          1992, and 1993, respectively.  Petitioner contends that travel              
          expenses were incurred by Special O for various trips taken by              
          petitioner and the other shareholders during 1991, 1992, and                
          1993.                                                                       
               A taxpayer is required to maintain records sufficient to               
          establish the amount of his or her income and deductions.  See              
          sec. 6001.  Under certain circumstances, where a taxpayer                   
          establishes entitlement to a deduction but does not establish the           
          amount of the deduction, the Court is allowed to estimate the               





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