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which the IRS accepted the Form 706 and the valuation of the La-
Z-Boy stock contained therein.
Under the terms of Selma Fritz' will, she bequeathed to Mr.
Fritz 75 percent of the rest, residue, and remainder of her
estate. The remaining 25 percent was bequeathed to petitioners'
son, Timothy R. Fritz. Included within the residue of Selma
Fritz' estate were her shares of La-Z-Boy stock. Upon receipt of
this stock, Mr. Fritz and Timothy Fritz placed the shares in a
stock account at the investment firm of A.G. Edwards & Sons, Inc.
(A.G. Edwards), in the names of Robert W. Fritz, Jennifer Joan
Fritz, and Timothy R. Fritz. In 1985, petitioners and Timothy
Fritz sold 5,406 shares of La-Z-Boy stock for $225,373.
Discussion
Car and Truck Expenses
On Schedule C of their 1987 Federal income tax return,
petitioners claimed a deduction in the amount of $21,364 for car
and truck expenses, which they argue represent expenses incurred
by Mr. Fritz in carrying on his tree trimming business. In the
notice of deficiency, respondent allowed only $11,721 of the
deduction, because petitioners failed to establish that all the
expenses claimed were paid and that they constituted ordinary and
necessary business expenses. Respondent's determination is
presumed correct, and petitioners bear the burden of proving
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