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be startup expenditures which would not be currently deductible
under section 195. Petitioners have failed to offer any
reasonable evidentiary basis by which this Court could make a
close approximation or estimate of petitioners' claimed
deductions.
We find that any attempt on the part of this Court to
estimate petitioners' repair and maintenance expense deductions
would amount to little more than guesswork because petitioners
have not provided credible evidence supporting petitioners'
claimed repair and maintenance expense deductions. Therefore, we
hold that petitioners are not entitled to claim repair and
maintenance expense deductions in the amount of $5,797 for the
1994 tax year.
h. Legal and Professional Services
Petitioners claimed legal and professional services expense
deductions in the amount of $806 on Schedule C of their 1994
Federal income tax return. It appears from the record that most,
if not all, of petitioners' claimed legal and professional
services expense deductions represented expenses for legal and
accounting work performed by Mr. Tijerina's firm.
Despite the fact that petitioners were represented by the
same accounting and legal firm at trial as they were for the time
petitioners operated Villa Cabana, neither counsel for
petitioners nor petitioners themselves produced any
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