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To substantiate the above expenses, petitioner introduced a
disorganized collection of checks, receipts, and barely legible
utility bills in addition to his testimony. Petitioner testified
that it was not until the eve of trial that he was able to obtain
these documents. Under the circumstances, however, petitioner's
efforts to obtain the documents he needed from Pugh both to
accurately prepare his return and to substantiate his deductions
at trial were minimal.
In addition, the checks submitted by petitioner did not
equal the amounts of the deductions argued for by petitioner on
brief for certain expenses.4 Therefore, the Court has examined
the documents provided to substantiate petitioner's deductions
and holds that petitioner is entitled to deductions in the
following amounts.
For 208 Oak Street, petitioner substantiated $838.99 for
advertising expenses, $2,396.52 for insurance, $9,146.98 for
utilities, $394.50 for meals and entertainment, $2,604.97 for
property taxes, $2,176.47 for cleaning and supplies, $2,096.36
for office and miscellaneous, and $4,362.32 for repairs and
maintenance and is entitled to deduct $419.50, $1,198.26,
$4,573.49, $157.80, $1,302.49, $1,088.24, $1,048.18, and
4 The amounts also differ from those originally reported
on petitioner's return because, petitioner asserts, "those
figures were based on estimates while the current figures are the
actual amounts."
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