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petitioners apparently rely on a stipulated exhibit to satisfy
their burden of proof. That stipulated exhibit (Exhibit 52) is
described as "a copy of ledger sheets pertaining to expenses
relating to the property in issue in the taxable years 1986,
1987, and 1988." Respondent, however, stipulates "only that
Petitioners' Exhibit 52 represents a listing of expenses relating
to the property in issue and does not stipulate that petitioners'
Exhibit 52 had any legal substance or represented bona fide debts
incurred by Good Shepherd." Petitioners have made no attempt to
tie the entries on Exhibit 52 to the deductions claimed on Good
Shepherd's returns. Petitioners have provided virtually no
documents, such as canceled checks, invoices, or bank statements
to back up the entries on Exhibit 52. Only one canceled check is
in evidence, a check in the amount of $25,000, drawn to Lino
Engineering Co. Vebeliunas testified that Lino Engineering was
contracted for "renovation and change" at the property. Thus, it
is not clear that the payment is deductible at all, because it
may well be a capital expenditure. See sec. 263(a). Also in
evidence are statements showing payments of $1,625, $2,887,
$6,250, $2,025, $325, $820, and $12,143 to various individuals in
1988. Since there are no deductions on Good Shepherd's return
for 1988 for (1) compensation to officers or (2) salaries or
wages, we assume that those payments, if made, were for
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