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into account in arriving at the initial figure of $2,477.
Petitioners argue that Mrs. Kerrigan used the Toronado for
business purposes 96 percent of the time. Exactly how this
figure was arrived at, one can only speculate. Petitioners also
contend that they are entitled to a mileage deduction for Mrs.
Kerrigan's use of a 1980 Mercedes 350 SL. No deduction for this
appears to have been claimed on their return. However,
petitioners do not explain why this mileage was not claimed on
their return, nor have they offered any evidence to prove what,
if any, use of the Mercedes was attributable to business.
Petitioners have not established an entitlement to deductions in
excess of the amount allowed by respondent. Accordingly, we
sustain respondent's disallowance.
Commission Expenses
Petitioners claimed a Schedule C deduction of $6,412.33 for
commissions paid by Mrs. Kerrigan in connection with the sale of
real estate in 1985. Respondent allowed a deduction of $3,927.
Petitioners attempted to prove that the additional commissions
were paid to their daughters. The testimony of the daughters was
vague as to how these "commissions" were computed, as well as to
their amounts. Moreover, Mr. Kerrigan observed at trial that his
daughters appeared to "overstate" the amount of their
commissions. Interestingly, the checks that petitioners offered
to substantiate these "commissions" were made payable to either
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