Earnest and Laura Tillman - Page 9

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          sold him the truck subject to the security interests of National            
          Bank of Detroit and Pro Am.4  A document was filed with the State           
          of Indiana, reflecting that Mr. Tillman purchased the 1988                  
          Peterbilt truck in 1987 for $71,944.  Later that year, the State            
          of Indiana issued a certificate of title to Mr. Tillman showing             
          that he owned the 1988 Peterbilt, and that the lienholders were             
          National Bank of Detroit and Pro Am.  Pro Am issued Mr. Tillman a           
          statement showing that his interest charges would be $10,513 for            
          1988, if he timely made all of his required payments.                       
                                       OPINION                                        
               Petitioners must prove that respondent's determinations set            
          forth in her notices of deficiency are incorrect.  Rule 142(a);             
          Welch v. Helvering, 290 U.S. 111, 115 (1933).  Respondent must              
          prove the increased deficiencies asserted in her amendment to               
          answer.  Rule 142(a); Estate of Bowers v. Commissioner, 94 T.C.             
          582, 595 (1990).                                                            
          1.  Additional Schedule C Expenses                                          
               An individual may deduct all ordinary and necessary expenses           
          paid or incurred during the taxable year in carrying on a trade             

          4 Mr. Tillman had borrowed $80,157 from Pro Am to acquire                   
          the 1988 Peterbilt.  The loan agreement states:                             
                    Borrower warrants and agrees that: * * * Borrower                 
               is the owner of the Collateral free from any liens,                    
               encumbrances or security interests except for the                      
               security interest granted hereby, and will defend the                  
               Collateral against all claims and demands of all                       
               persons at any time claiming the same or any interest                  
               therein; * * *                                                         




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