- 8 - 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 eitherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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