Marian and Halina Januszewski - Page 8

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          premium refund.  Thus, respondent allowed $3,721 in insurance               
          expenses.  The record supports respondent's position.                       
          Repairs and Maintenance                                                     
               Petitioners reported repairs and maintenance expenses in the           
          amount of $6,987.80 on their amended return.  However,                      
          petitioners submitted into evidence receipts, including newly               
          discovered receipts for $703 and $243, which totaled $3,777.86.             
          Respondent conceded this amount but reduced it by 15 percent                
          because respondent contends this represents petitioners' personal           
          use of the vehicle.  Thus, respondent's position is that                    
          petitioner should be allowed repairs and maintenance expenses in            
          the amount of $3,211.                                                       
               With respect to the difference of $3,209.94 ($6,987.80 -               
          $3,777.86), petitioners introduced into evidence a reconstructed            
          summary sheet for service and parts from an auto repair service             
          station in the amount of $3,210.  After a review of this invoice,           
          we are not satisfied that it is an accurate and credible                    
          document.  We note that many of the items listed in the                     
          reconstructed summary sheet were also listed in other invoices              
          which respondent had allowed previously.  Petitioners failed to             
          provide any reasonable explanation for the duplication.  Further,           
          petitioners failed to provide any receipts, canceled checks, or             
          credit card statements to prove that those expenses listed in the           
          summary sheet were incurred and paid.  Accordingly, we find that            





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