Juan N. and Miriam J. Villareal, et al. - Page 13

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          Schedule C.  Petitioners' 1995 transaction report lists monthly             
          insurance payments in the amount of $113.36.                                
               On the basis of the record, we are satisfied that                      
          petitioners paid regular monthly premiums for business liability            
          insurance.  Accordingly, we hold that petitioners are entitled to           
          a deduction in the amount of $113.36 for the 1994 tax year                  
          representing expenses incurred for business insurance for the               
          month of December 1994.                                                     
               f.  Food, Restaurant Supplies, and Soda Purchases                      
               Though petitioners' 1994 transaction report lists expenses             
          for food, restaurant supplies, and soda in the amount of                    
          $4,565.74, petitioners did not claim expense deductions for food,           
          restaurant supplies, or soda purchases on their 1994 Schedule C.            
               Petitioners did not purchase food and cleaning supplies from           
          just one vendor.  In order to get the lowest price, or for                  
          convenience if the store was in the same shopping mall as Villa             
          Cabana, petitioners would purchase restaurant items at different            
          stores.  Petitioners' 1994 transaction report indicates, however,           
          that petitioners purchased soda from only one commercial                    
          restaurant supply vendor.  Once again, the record does not                  
          indicate that petitioners made any attempt to contact vendors in            
          order to substantiate food, restaurant supplies, or soda expenses           
          for 1994.                                                                   
               Though petitioners' 1994 transaction report lists expenses             
          for food, restaurant supplies, and soda in the amount of                    




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