Joseph W. Evans, Jr. and Mildred S. Evans - Page 2




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          hearing, and we conclude that a hearing is not necessary.  Rule             
          232(a)(3).  We decide the matter before us based on the record.             
               In a statutory notice of deficiency dated November 1, 1994,            
          respondent determined a deficiency in petitioners' 1992 Federal             
          income tax in the amount of $7,888 and an accuracy-related                  
          penalty pursuant to section 6662 in the amount of $1,578.  In the           
          notice of deficiency, respondent disallowed the following                   
          expenses claimed by petitioners on their 1992 return on the                 
          ground that petitioners had not substantiated the claimed                   
          deductions:                                                                 
               Schedule C      Auto expenses*       $7,583                            
               Schedule C      Supplies**            4,639                            
               Schedule C      Travel                1,745                            
               Schedule C      Meals and                                              
                              entertainment         1,289                             
               Schedule E      Expense              10,908                            
               Schedule E      Depreciation          4,505                            
               Schedule A      Taxes                   565                            
               *  This amount consists of auto expenses of $3,743 from                
               Primerica Schedule C and commissions of $3,840 from the                
               Product Wholesale Distribution Schedule C.                             
               ** This amount consists of $2,886 for supplies claimed                 
               on the Primerica Schedule C and $1,753 for supplies                    
               claimed on Product Wholesale Distribution Schedule C.                  
               Respondent also increased a $5,248 tax on an early                     
          distribution reported by petitioners on their return to $6,268,             
          resulting in an upward adjustment of $1,020.                                
               Petitioners timely filed their petition on January 30, 1995,           
          in which they disagreed with each of respondent's above-mentioned           
          adjustments.                                                                
               After the petition was filed, the case was assigned to an              
          Appeals officer in Tampa, Florida.  Because the principal issue             

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