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did not take into account any tips, which would have increased
the total gross receipts up to 15 percent. We have considered
petitioner's miscellaneous objections to Mr. Savage's
calculations and, after carefully reviewing the record, are
convinced that the cab formula used by Mr. Savage clearly
reflects petitioner's gross receipts for 1992 and 1993. We
therefore sustain respondent's determinations of petitioner's
unreported income.
The second issue for decision is whether petitioner is
entitled to Schedule C business expense deductions in excess of
the amounts allowed by respondent.
Petitioner claimed a deduction for car and truck expenses
for 1992 in the amount of $16,200. In the statutory notice of
deficiency, respondent disallowed $7,473 of the claimed expenses.
Petitioner also claimed a deduction for repairs to his taxicab
for 1993 in the amount of $3,055. Respondent disallowed $1,644
of the claimed repairs.
Respondent's explanations in the statutory notice of
deficiency state that the amounts were disallowed because
petitioner did not establish that any amounts over the allowed
amounts were ordinary and necessary business expenses, and that
the section 274 substantiation requirements had not been met.
Section 162(a) provides for the deduction of all ordinary
and necessary expenses paid or incurred during the taxable year
in carrying on any trade or business. Deductions are strictly a
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