James K. Roberts - Page 14

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          Rallye Motors, he incurred expenses incident to that employment             
          for which he did not feel it was proper to claim reimbursement.             
          Petitioner has provided no detail of any expenses he may have               
          incurred.  Petitioner has failed to convince us that, during                
          1988, he incurred any unreimbursed, business-related expenses.              
          Petitioner has failed to carry his burden of proof on this issue,           
          and we sustain so much of respondent’s determination as relates             
          thereto.                                                                    
                    3.  Schedule C Deductions                                         
               In her notice of deficiency, respondent included adjustments           
          disallowing “Schedule C Expenses” for 1987 and 1988 in the                  
          amounts of $5,331 and $4,745, respectively.  After taking into              
          account concessions by the parties, only the following expenses             
          remain in dispute:                                                          
                                             1987      1988                           
               Car & truck              $687      $815                                
               Dues                          185       122                            
               Office, rent & utilities     1,651     1,691                           
               Supplies                      68        263                            
          Those expenses were claimed by petitioner on Schedules C, Profit            
          or Loss From Business, attached to petitioner’s Forms 1040 for              
          1987 and 1988, respectively.  Those Schedules C identify the                
          trade or business in question as horse racing and breeding.                 
               Respondent has allowed substantial amounts as deductions in            
          connection with petitioner’s horse racing and breeding business.            
          Petitioner has not convinced us that he incurred deductible                 





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