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Feltrinelli paid a $5,000 franchise fee to the Owens in 1989 or
1990.
c. Payments for The Owens' Children's College
Education
Mr. and Mrs. Owens contend that they may deduct $8,200 in
1989 and $8,100 in 1990 that they gave to their children to go to
college. Mr. and Mrs. Owens testified generally that their
children worked as needed for their businesses. Mr. and Mrs.
Owens did not keep records of this work. We conclude that Mr.
and Mrs. Owens may not deduct these amounts.
d. Other Claimed Deductions and Cost of Goods Sold
There is no evidence to support petitioners' contentions
that they may deduct more than respondent allowed for charitable
contributions, wages for part-time help, utilities, insurance,
interest and taxes, a tractor, a low boy trailer, a tanker truck,
and car and truck expenses, or that their cost of goods sold was
more than respondent allowed. Mrs. Owens testified that she lost
some of the truck expense and car deduction records for the years
in issue, but petitioners did not offer enough other evidence to
show that they may deduct these items. Respondent conceded that
petitioners may deduct some items based on statements by
petitioners. For example, respondent concedes that petitioners
may deduct some payments for utilities, goods and supplies, and
employees' wages.
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