Juan N. and Miriam J. Villareal, et al. - Page 10

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               In this instance, any attempt on the part of this Court to             
          estimate petitioners' depreciation or section 179 deductions, or            
          petitioners' basis in any equipment they may have purchased,                
          would amount to little more than guesswork.  Therefore, we hold             
          that petitioners are not entitled to such deductions because they           
          have failed to substantiate the underlying cost of the assets on            
          which the deductions are claimed.                                           
               c.  Car and Truck Expenses                                             
               Though petitioners claimed car and truck expense deductions            
          in the amount of $10,884 on Schedule C of their 1994 Federal                
          income tax return, they did not list car and truck expenses on              
          their 1994 transaction report.                                              
               Petitioner testified that he shopped for restaurant supplies           
          and produce but did not present any substantiating evidence                 
          regarding the business use of petitioners' vehicle.  Much of                
          petitioner's shopping took place at stores within the same                  
          shopping center as Villa Cabana, and we have no evidence as to              
          petitioners' vehicle use, mileage, or even the method petitioners           
          used in arriving at the $10,884 amount.                                     
               Indeed, the car and truck expense deduction amount claimed             
          by petitioners may be a mistaken entry, since petitioners claimed           
          depreciation and section 179 expense deductions in the amount of            
          $10,884 on Form 4562, but did not report that amount on Schedule            
          C, line 13.                                                                 






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