-49- 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.Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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