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Pont, 308 U.S. 488, 495-496 (1940). Ordinarily, an expense is
necessary if it is appropriate and helpful to the operation of
the taxpayer's trade or business. Commissioner v. Tellier, 383
U.S. 687, 689 (1966); Carbine v. Commissioner, 83 T.C. 356, 363
(1984), affd. 777 F.2d 662 (11th Cir. 1985).
To substantiate their claimed deductions for automobile
expenses, petitioners rely on the testimony of Mr. Katerelos and
a document he prepared three weeks prior to the trial herein that
purports to reconstruct in very summary fashion the business use
of his automobile (summary). We are unwilling to rely on the
testimony of Mr. Katerelos or on the document he prepared in
anticipation of trial to prove either (1) that petitioners
actually incurred such expenses or (2) that if such expenses were
incurred, they were ordinary and necessary expenses with respect
to petitioners' business, NDV.
With respect to Mr. Katerelos' testimony regarding the
automobile expenses at issue, in addition to our having found
that his testimony is generally not credible, his testimony with
respect to his use of an automobile for NDV's business is in
conflict with an insurance application he signed in May 1988 for
the Lincoln that he claims he used for business purposes through-
out 1987 and during 1988 until he purchased a 1987 Cadillac. In
that application, the box marked "no" was checked in response to
a question as to whether the Lincoln was used for business
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