Greta Ann Clifton - Page 19

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          and $109.  In regard to the $218 expenditure, petitioner                    
          presented a cancelled check to Lama Tours International dated               
          August 14, 1985, a Braniff airlines receipt dated August 15,                
          1985, and testimony regarding the business purpose of the trip.             
          However, with regard to the two remaining checks, petitioner                
          could not recall the time and place of each trip, nor could she             
          remember the business purpose for each trip.  We find that                  
          petitioner has adequately substantiated her entitlement to a $218           
          travel and entertainment deduction.  As to the remainder of the             
          amount claimed, we sustain respondent's determination.                      
               G.  Utilities and Telephone                                            
               Petitioner claimed a $482 deduction for utilities and                  
          telephone on her 1985 Federal income tax return.  Respondent                
          determined that such amount was not allowable.  Subsequently,               
          respondent allowed $332 of this amount.  The remaining $150 is in           
          dispute.                                                                    
               Petitioner offered no evidence to show that she is entitled            
          to any expense for utilities and telephone in an amount greater             
          than $332.  Since petitioner has failed to sustain her burden of            
          proof, we affirm respondent's determination.                                
               H.  Contract Labor                                                     
               Petitioner claimed a $1,288 deduction for contract labor on            
          her 1985 Federal income tax return.  Respondent determined that             
          $654 of such amount was not allowable.  Subsequently, respondent            
          allowed an additional deduction of $580.  Thus, respondent                  




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