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three individual accounts. On her 1985 Federal income tax
return, petitioner deducted the entire $105 in bank charges. In
her notice of deficiency, respondent disallowed this deduction.
Petitioner argues that, since she conducted her Avon
business through these three accounts, the service charges are
deductible. However, petitioner conceded that she also used the
accounts for "personal" purposes. Petitioner did not attempt to
quantify the personal use versus the business use. Respondent
conceded that petitioner was entitled to deduct $24 of the $105
in service charges, apparently recognizing that the portion of
the service charges attributable to the Avon business was
deductible. Petitioner has failed to substantiate that the
remaining $81 claimed was a deductible business expense.
Therefore, we sustain respondent's determination.
B. Car and Truck Expenses
Petitioner claimed a deduction of $1,564 for car and truck
expenses on Schedule C of her 1985 Federal income tax return.
Respondent determined that only $420 of such amount was
allowable. Petitioner asserts that the entire amount claimed is
allowable.
When a taxpayer uses a vehicle for both business and
personal purposes, she must produce sufficient evidence by which
this Court can determine what portion of such expenses was for
business purposes and what portion was for personal purposes.
Cobb v. Commissioner, 77 T.C. 1096, 1101 (1981).
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