Robert W. and Jennifer J. Fritz - Page 6

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          Amoco.  It is unclear what charges these checks were intended to            
               Finally, petitioners introduced adding machine "tape totals"           
          that were attached to the charge slips they introduced.  These              
          "tape totals" contain two line items for which no charge slips              
          can be found.  One line item is for $2,113.57.  The only evidence           
          of its payment is a piece of the "tape total" stapled to a series           
          of charges from Carter's Amoco for purchases in April 1987.  On             
          the tape piece is the notation "Paid in full".  The other line              
          item is for $1,192.09.  The only evidence that this amount was              
          paid is a handwritten notation appearing on a January 2, 1987,              
          charge slip from Carter's Amoco stating "Pd in full 1192.09 1-2-            
          87".  The handwriting appears to be different from the                      
          handwriting of the person that prepared the charge.                         
               Even including these two line items from the "tape totals"             
          and the carbon copies of the checks from Dollar Bank, petitioners           
          have presented evidence that they paid only $9,759.71 of car and            
          truck expenses for 1987.  This figure falls short of the amount             
          already allowed by respondent.  Petitioners have also failed to             
          prove that these expenses were ordinary and necessary business              
          expenses within the meaning of section 162(a).  Neither the                 
          charge slips nor the copies of the checks from Dollar Bank                  
          indicate the requisite business purposes for petitioners'                   
          expenditures.  See sec. 1.162-1(a), Income Tax Regs.  We                    
          therefore sustain respondent's determination.                               

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