Ronald D. Ciaravella - Page 12

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                                         Schedule C - Innovative                      
                                        1992                  1993                    
          Gross receipts           $59,041               $114,066                     
          Expenses:                                                                   
          Advertising1                  8,014                  3,118                  
          Commissions & fees            550                    -0-                    
          Depreciation                  5,775                 215,100                 
          Rental or lease               1,015                    321                  
          of vehicles, machinery,                                                     
          & equipment                                                                 
          Repairs & maintenance     37,046                 86,002                     
          Taxes and licenses            129                    811                    
          Travel, meals &               3,674                  5,309                  
          entertainment                                                               
          Fuel                          4,619                 10,702                  
          Other expenses3               2,357                  2,609                  
          Total expenses           63,178                123,972                      
          Profit (Loss)            (4,137)                (9,906)                     
               1These expenses refer to the payments made by Innovative to            
          trade publications in which Dolphin advertised.                             
               2The depreciation deduction was claimed on both the race car           
          and a trailer used to transport the car to race locations.  The             
          trailer was purchased in 1993.                                              
               3Boat fuel expenses relating to the fuel provided by Dolphin           
          to power boats were listed under this category.  See infra p. 13.           
          Respondent disallowed all deductions claimed by Mr. Ciaravella on           
          the Innovative Schedules C on the ground that the expenses were             



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