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totaling $55,369, $53,376, and $49,495, respectively.
Specifically, the Schedules F reflected the following:
1991 1992 1993
Part II--Farm Expenses
Chemicals $1,467 $1,540 $1,815
Custom hire (machine work) 4,335 4,110 3,765
Depreciation 3,780 2,980 3,028
Fertilizers and lime 6,238 5,750 4,872
Freight and trucking 2,150 1,863 1,605
Gasoline, fuel, and oil 4,610 4,974 3,840
Insurance (other than health) 3,375 3,980 3,980
Interest:
(b) Other 4,135 3,318 3,648
Labor hired (less jobs credit) 3,498 2,514 2,690
Repairs and maintenance 5,854 7,579 5,173
Seeds and plants purchased 6,775 6,315 5,155
Storage and warehousing 1,200 1,200 1,200
Supplies purchased 1,992 1,655 2,140
Taxes 726 810 840
Utilities 1,241 905 1,892
Other expenses 3,993 3,883 3,852
Total expenses 55,369 53,376 49,495
Net loss 54,409 52,161 48,395
Respondent allowed expenses to the extent of petitioner's
reported Schedule F income for each year in issue. Respondent
disallowed the remaining deductions claimed on the ground that
petitioner failed to establish that the expenses were ordinary
and necessary within the meaning of section 162 and for lack of
substantiation.
Respondent's determinations, having been made in a notice of
deficiency, are presumed correct, and petitioner bears the burden
of proving such determinations to be erroneous. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933). Furthermore,
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