Leo and Alla Goldberg - Page 49

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          Respondent disallowed $13,188 of expenses related to the vehicle            
          resale business and $28,417 of expenses related to the business             
          school, based on her position that petitioners did not pay the              
          claimed expenses with their own funds.  Petitioners contend that            
          they are entitled to these deductions because they reported the             
          corresponding income from these activities on their 1991                    
          Schedule C.  We have concluded that petitioners exercised the               
          requisite dominion and control such that the funds received from            
          Kortava for the vehicle resale business and the business school             
          are includable in petitioners' gross income.  Thus, the expenses            
          that petitioners incurred in the operation of the Schedule C                
          businesses that have been properly substantiated and that are               
          ordinary and necessary are deductible by them.                              
               Vehicle Resale Business                                                
               To substantiate disallowed deductions claimed in relation to           
          the vehicle resale business, petitioners introduced an exhibit              
          that included various receipts and their 1991 tax return.                   
          Petitioner also testified at trial as to the existence of the               
          various expenses.                                                           
               The information contained on a tax return is not proof of              
          the amount of deductions contained therein.  Wilkinson v.                   
          Commissioner, 71 T.C. 633, 639 (1979).  Although petitioner                 
          testified to the contrary, the exhibit introduced at trial did              
          not contain receipts for gas or office expense.  We require more            
          than petitioner's unsubstantiated and unverified testimony as to            
          the existence of gas expense and office expense.  Wood v.                   



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