Curtis G. and Edna L. Lockett - Page 6

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          reached, the case would be recalendared for trial.  Over 1 year             
          later, the parties had failed to agree on a settlement; whereupon           
          the case was recalendared for completion of the trial.                      
               The evidence presented by petitioner to substantiate his               
          expenses was scant.  Although he produced copies of a series of             
          canceled checks, many of the checks were payable to cash, and no            
          receipts, bills, or invoices were produced to corroborate or                
          associate any of the checks with the expense purportedly being              
          paid.  Moreover, as to each of the expenses at issue, the checks            
          submitted to support the expense claimed did not add up to or               
          equal the amount claimed as an expense on the return.                       
          Petitioner's basic answer was that he could not "come up" with              
          the missing checks.  Moreover, the evidence fails to support a              
          finding that petitioner was engaged in a trade or business during           
          the years in question.  Petitioner acknowledged that he was no              
          longer in the building construction business during 1991 and                
          1992, and the Court is satisfied that petitioner was not engaged            
          in a medical research and development activity during the 2 years           
          at issue.  At best, petitioner was attempting to start or begin             
          an activity in medical research, and the evidence falls short of            
          establishing that such an activity ever commenced or was likely             
          to commence.                                                                
               Section 162(a) provides generally that there shall be                  
          allowed as a deduction all the ordinary and necessary expenses              

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