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itemized deductions that are allowable for that year.3
Accordingly, the refund of State income tax in the amount of $414
in 1994 is not includable in petitioner's gross income for that
year.4
Issues (7) and (8): Schedule E Deductions - 1994
Respondent disallowed entirely Schedule E deductions claimed
by petitioner in 1994 for cleaning and maintenance, repairs, and
utilities. At trial, respondent conceded that petitioner had
substantiated, and was therefore entitled to deduct, expenses for
cleaning and maintenance in the amount of $600 and repairs in the
amount of $1,350. The balance of such deductions, and the entire
deduction claimed for utilities, remain in issue.
At trial, petitioner introduced no persuasive evidence that
he is entitled to deductions for cleaning and maintenance and for
repairs in excess of the amounts conceded by respondent.
Accordingly, we sustain respondent's determination as modified by
respondent's concession at trial.
Insofar as the deduction for utilities is concerned, the
record does not permit a finding that petitioner expended the
amount claimed on his return (i.e., $800). However, we are
satisfied that petitioner did, in fact, incur expenses for
3 For 1993, an individual with a "single" filing status is
entitled to a standard deduction in the amount of $3,700. Sec.
63(c). This amount exceeds petitioner's allowable itemized
deductions (i.e., State income tax in the amount of $2,043).
4 See supra note 2.
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