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granted, and the case was recalendared for September 22, 1997.
Finally, the case was continued from that date and recalendared
for January 26, 1998. The Court notes that the only records
obtained by petitioners during this entire period and submitted
in evidence were 15 canceled checks for the period June 26, 1990,
through July 12, 1990.
a. Advertising. Petitioner testified that JDB did
extensive advertising by flyer and in the “Yellow Pages” of the
telephone book. Considering the nature of the business, we are
surprised by this claim, in that petitioners’ clients were real
estate developers and not the general public. Moreover, it would
have been a simple task to contact the telephone company or
printers to obtain verification of their claimed advertising
expense. On this record, we cannot allow any amount for
advertising.
b. Car and truck. Petitioner claimed that they had two
vehicles solely for business, in addition to petitioner wife’s
personal auto, which was used for nonbusiness purposes. However,
no records were ever maintained for the vehicles’ usages, no
records were kept for the actual expenses incurred for these
vehicles, and no evidence was submitted regarding their cost.
Accordingly, because there is no compliance with the requirements
of section 274(d), no amount can be allowed for car and truck
expense.
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