Leo and Alla Goldberg - Page 50

                                        -50-                                          
          Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.              
          593 (1964).                                                                 
               One repair receipt totaling $125 and marked paid is included           
          in petitioners' exhibit.  This additional amount will be allowed.           
               As for additional vehicle expenses, we cannot determine from           
          the receipts in evidence that petitioners are entitled to any               
          deductions other than those already allowed by respondent.                  
          Petitioners claimed that they did not include the value of their            
          Mercedes that they shipped to Russia as an expense when they were           
          preparing their 1991 Schedule C.  Petitioner testified that the             
          Mercedes was worth $20,000 when it was shipped to Russia.                   
          Kortava testified that the Mercedes was worth approximately                 
          $10,000.  The damage report that was completed before shipping              
          notes that the Mercedes had several minor scratches and a broken            
          headlight, as well as additional damage.  No additional evidence            
          was presented to show the value of the 1984 Mercedes.  We found             
          as a fact that petitioners received $20,000 in 1990 from Kortava            
          as consideration for petitioner's sending his Mercedes to Russia            
          and that petitioners did not recognize a gain from this                     
          transaction.  The record does not provide any evidence that the             
          Mercedes ever became the property of Coastline.  Thus, the                  
          transaction took place outside of the Schedule C vehicle resale             
          business, and petitioners are not entitled to a deduction on                
          their 1990 Schedule C for the expense of the Mercedes.                      






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