4
these amounts, $1,800 and $1,770 in 1993 and 1994 were payable to
Mrs. Olvera. Petitioner wired an additional $550 to Mrs. Olvera,
but it is not clear when this transfer was made. Petitioner
traveled to Mexico twice in 1993 and once in 1994. On these
trips he carried cash, which he gave to his relatives.
During the years in issue, in addition to other employment,
petitioner delivered pizzas on a part-time basis for Father & Son
Pizza. Petitioner was required to provide his own car for use in
delivering pizzas. Father & Son Pizza recommended that drivers
carry cellular phones because the safety of the neighborhoods on
the delivery routes was uncertain. In 1993 petitioner borrowed a
cellular phone for this use. In 1994 petitioner purchased a
cellular phone. Petitioner did not maintain any records with
respect to his automobile or cellular phone usage or expense.
On their joint Federal income tax returns filed for 1993 and
1994, petitioners claimed dependency exemption deductions with
respect to their two daughters and with respect to petitioner's
mother and his sister Zulma Olvera. On Schedule C of their 1993
return, petitioners reported gross receipts of $3,808 from
petitioner's pizza deliveries and claimed deductions for car
expense and utilities expense in the amounts of $2,484 and $474,
respectively. On Schedule C of their 1994 return, petitioners
reported gross receipts of $3,091 from petitioner's pizza
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