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expenses beyond what respondent already has allowed. For
instance, in support of the disputed car and truck expense for
1987, petitioner introduced into evidence a $300 invoice for the
installation of a car phone in a new Mercedes automobile.
Petitioner has failed to convince us that that expense did not
have substantial, if not exclusive, personal attributes. He has
failed to convince us that his 1988 car and truck expense related
to a vehicle used in his business. Also, he has failed to
provide any detail or supporting documents concerning the
category “Office, Rent, & Utilities”. He testified that the
category “Dues” included magazine subscriptions. Petitioner has
not proven that any of the disallowed expenses were incurred in
connection with his business of horse racing and breeding.
Accordingly, we sustain so much of respondent’s determination as
relates thereto.
III. Disputed Additions to Tax
A. Failure To File--1987
By her notice of deficiency, respondent determined an
addition to tax against petitioner under section 6651(a)(1) for
1987. Section 6651(a)(1) provides that, in the case of a failure
to file an income tax return by the due date, there shall be
imposed an addition to tax for such failure of 5 percent of the
amount of tax, reduced by timely payments and credits under
section 6651(b)(1), for each month or portion thereof during
which the failure continues, not exceeding 25 percent in the
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