Sony and Gwendolyn A. Jean Baptiste - Page 7




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          taxpayer presents evidence sufficient to provide some rational              
          basis upon which estimates may be made.  Vanicek v. Commissioner,           
          85 T.C. 731, 743 (1985).                                                    
               The only documentary evidence petitioner provided to                   
          substantiate the claimed deductions were the computer printouts.            
          Petitioner testified that he no longer had any receipts or other            
          records.  Petitioner did not offer any testimony regarding taxes            
          and licenses, travel, uniforms, beeper, and tools.  We assume               
          that petitioners have conceded these issues.  Therefore, we shall           
          address only the expenses for wages, truck rent, fuel, and unpaid           
          dispatch.                                                                   
               Petitioners claimed an expense for wages in the amount of              
          $1,190.  This expense was for the amounts that petitioner paid              
          the lumpers to help unload the trucks.  Petitioner would obtain             
          advances from Ortega for this purpose.  Repayment of these                  
          advances would be made by deductions from petitioner’s wages.               
          The computer printouts from Ortega substantiate petitioner’s                
          claim.  We find that petitioners have substantiated the amount              
          that petitioner paid the lumpers and are entitled to a deduction            
          of $1,190.6                                                                 
               Petitioners deducted $1,878 for truck rent.  Petitioner                
          testified that this amount is composed of the escrow balance and            
          the VAF.  After studying the computer printouts, we find that no            

               6  We note that according to the printouts, petitioner                 
          received $2,410 in company advances.  Some of these advances were           
          for large amounts and may have been for other purposes that                 
          petitioner did not specify.                                                 


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