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Petitioners claimed utilities expenses in the amount of
$2,937, which respondent disallowed in full. Mrs. Brown
testified that Mr. Brown used the telephone in petitioners' home
to arrange work projects and to receive calls regarding potential
jobs. Additionally, Mrs. Brown testified that petitioners paid
for water, telephone, and electricity at the Fruitdale shop. On
the basis of the record in the instant case, we are persuaded
that petitioners incurred allowable business expenses (i.e.,
expenses other than the personal expense of the first telephone
line provided to petitioners' residence, see sec. 262(b)) to some
extent for such items. Accordingly, we approximate petitioners'
utility expenses to be $1,500 during 1991.
Petitioners claimed bank charge expenses in the amount of
$146, which respondent disallowed in full. At trial, petitioners
provided no evidence or testimony to substantiate the amount or
the purpose of the bank charge expense deduction that they
claimed. Consequently, as there is no rational basis to
approximate such expenses, we conclude that petitioners have not
met their burden of substantiating them. Rule 142(a). In sum,
as to petitioners' Schedule C business expenses, we conclude that
petitioners have substantiated expenses in the amount of
$158,038.52.
We turn to examine the Schedule A deductions in issue. On
their 1991 return, petitioners claimed Schedule A itemized
deductions in the amount of $29,305. In the notice of
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