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The list, which was not compiled contemporaneously, consists of
petitioner's estimates. The record also contains several of
petitioner's monthly credit card statements dated 1987,
purportedly indicating that petitioners incurred startup expenses
attributable to the purchase of tack and other supplies in the
amount of $6,864.
Petitioners' list is inadequate for the purposes of
substantiating the expenses in question. Petitioner did not
contemporaneously compile the list, and we do not accept
petitioner's self-serving estimates of the expenditures in issue.
Cf. Farguson v. Commissioner, T.C. Memo. 1983-615 (rejecting
taxpayer's poorly detailed and noncontemporaneous ledger as
inadequate for substantiating purported expenses). Furthermore,
many of the expenditures in question relate to the purchase of
bridles, saddles, and other equipment which had a useful life
beyond the year in which they were purchased. These expenditures
are capital expenditures, and cannot be considered as startup
expenditures. S. Rept. 96-1036, supra at 12; sec. 1.263(a)-2(a),
Income Tax Regs.; cf. Rodgers Dairy Co. v. Commissioner, 14 T.C.
66, 71 (1950) (allowing taxpayer's claim for depreciation with
respect to bridles and saddles). Although the credit card
receipts indicate that petitioners may have incurred expenses
related to their horse-breeding and racing activities prior to
1988, we cannot discern from the record those items constituting
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