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appears to have fabricated the logs in order to substantiate his
claimed deductions.
The evidence does not show that petitioner used the
depreciated property in a trade or business or held it for the
production of income; furthermore, petitioner presented no
evidence regarding the Schedule E depreciation expenses. We
therefore sustain respondent's determination on this issue.
B. Wage, Leasing, and Car and Truck Expenses
Section 162 allows a deduction for all of the ordinary and
necessary expenses paid or incurred in carrying on a trade or
business. Respondent did not allow petitioner deductions for
leasing expenses in 1985, 1986, and 1987 or car and truck
expenses in 1985 and 1986.
1. Wage Expenses
Petitioner claimed wage expenses in the amounts of $14,401,
$13,869.04, and $15,998 in 1985, 1986, and 1987, respectively.
Respondent allowed petitioner wage expenses in the amounts of
$11,325, $10,800.04, and $12,000 in 1985, 1986, and 1987,
respectively. Respondent argues that petitioner has failed to
substantiate deductions in amounts greater than those allowed;
petitioner claims that he has substantiated his claimed
deductions.
Petitioner did not testify regarding whom he employed in his
medical practice. Ms. Alshabani testified that she was employed
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