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at issue. However, the summary is titled “supplies”, and there
are no disputed deductions on the supplies issue.
Exhibit 102 is most deficient, however, with respect to the
copies of the receipts included therein. There is no indication
of the relationship between the additional expenses and the
corporations' business. In order to be deductible, a business
expense must be an ordinary and necessary expense of doing
business. Sec. 162(a). The receipts do not show the ordinary
and necessary business purposes of the expenses, but rather
reflect mostly personal items, including groceries and minor
office supply items. Even with the supply items listed, there is
no way to determine whether these receipts correspond to the
additional deductions claimed. Exhibit 102 does not carry
petitioners’ burden of substantiating the office expense
deductions. Therefore, we uphold respondent’s determination on
the office expenses.
Petitioners claim additional travel and entertainment
expenses for GAPS of $11,119 and for JJM of $3,565. Petitioners’
claim that exhibit 104 supports these deductions. Respondent
objects to the exhibit on the grounds of relevancy, lack of
completeness, hearsay, and lack of trustworthiness.
As with exhibit 102, we find it unnecessary to rule on
respondent’s objection, because the evidence on the claimed
travel and entertainment deductions is similarly deficient. Even
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