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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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