-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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