Robert A. Inzano and Martha O. Chavez - Page 10

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          repairs, no substantiating evidence was presented.  We sustain              
          respondent’s disallowance of this item.                                     
               g. Supplies.  Petitioners purchased supplies such as window            
          washing solution and a compound used for removing materials stuck           
          to glass.  Canceled checks submitted verify the purchase of                 
          supplies on July 7, 1990, for $42.50.   On this record and using            
          our best judgment, we allow petitioners a deduction for supplies            
          of $600.  Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).                
               h.  Taxes and licenses.  Petitioner testified that he had to           
          purchase a municipal business license whenever JDB had to go into           
          a new municipality.  Each license was valid for one year.  We               
          kept the record open for petitioners to contact the various                 
          municipalities to obtain substantiating documentation.  Nothing             
          was received.  On this record, we have no basis upon which to               
          estimate or allow a deduction for expenses for licenses.  Vanicek           
          v. Commissioner, 85 T.C. 731 (1985).                                        
               i.  Labor.  We find that petitioners hired outside labor to            
          perform the services required.  We also find that petitioners               
          performed some of the services themselves.  Canceled checks for             
          such labor for the period June 26, 1990, through July 7, 1990,              
          totaled $2,890.  Based upon this record, we allow petitioners a             
          deduction for labor of $10,000.  Cohan v. Commissioner, supra.              
               The final issue to be decided is whether petitioners are               
          liable for an addition to tax pursuant to section 6651(a)(1).               





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