Marcus Wayne and Judity Caroline Ramsey - Page 13

                                        -13-                                          
          previously claimed Schedule A unreimbursed employee business                
          expenses  as  Schedule  C  business  expenses  associated  with             
          petitioner’s services as an “independent contractor”.  Petitioners          
          also increased the amount of the deduction from $51,363.96 to               
          $57,348. The expenses claimed on Schedule C were:                           
                    Advertising                      $513                             
                    Bad debt                       10,000                             
                    Car operating expenses          6,201                             
                    Depreciation (car)              2,850                             
                    Depreciation (house)           10,300                             
                    Employee benefits (life         1,424                             
          insurance)                                                                  
                    Interest (car)                  1,660                             
                    Office expense                  4,046                             
                    Supplies                        9,023                             
                    Travel                          7,465                             
                    Meals/entertainment             4,832                             
                    (less 20 percent of meals and                                     
          entertainment)                  (966)                                       
          Total                         $57,3487                                      
               Discussion                                                             
               Deductions are a matter of legislative grace.  New Colonial            
          Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).  Taxpayers bear the         
          burden of establishing that they are entitled to the claimed                
          deductions.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 114             
          (1933).  This includes the burden of substantiating the amount and          
          purpose of the item claimed.  Sec. 6001; Hradesky v. Commissioner,          
          65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.              



               7    The parties stipulated that petitioners are not                   
          entitled to the $10,000 bad debt deduction.                                 






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