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At trial and on brief, petitioners provide confusing
information and ambiguous arguments concerning these two
transactions with Christa Oil. During the trial, in response to
a question from the Court as to whether petitioners had attempted
to obtain the original records of Christa Oil, or its successor,
regarding these transactions, the following dialogue occurred
between the Court and petitioners' counsel:
THE COURT: Mr. Lumerman, do you know the status of Christa
Oil and the records? Have you made any attempt to get the
records of Christa Oil with regard to the purchase by it of
the stock from Mrs. Leavell?
MR. LUMERMAN: No, Your Honor, frankly, we haven't.
We sustain respondent's determination on this issue in its
entirety.
Expenses of Various Businesses
L & L Supply
As indicated, in 1984, Eva started an oil equipment sales
business under the name of L & L Supply. On Schedules C attached
to petitioners' joint Federal income tax returns for 1985, 1986,
and 1987, Eva claimed operating and/or trucking expenses of
$106,801, $53,941, and $124,454, respectively, relating to this
business. On audit, respondent disallowed for lack of
substantiation these claimed expenses of L & L Supply.
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