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respondent on January 5, 1998, respondent requested a hearing in
this matter. We conclude that a hearing is not necessary. We
decide petitioners' motion based on the record. The record
consists of petitioners' motion for costs with attached affidavits,
respondent's notice of objection to petitioners' motion for costs,
and the uncontroverted statements by the parties as contained in
the aforementioned documents.
On their 1993 joint Federal income tax return,
petitioners claimed, inter alia, itemized deductions of
$36,594, an advertising deduction on Schedule C2 of $43,362
and other Schedule C expenses in the amount of $100,362. The
$100,362 claimed expenses consist of:
1. Credit Reports #6064 $28,610
2. Business Development #6073 20,932
3. Loan Costs #6067 24,706
4. Contract Labor #6068 13,228
5. Costs of Funds #6079 12,886
100,362
Upon audit of petitioners' 1993 return, respondent
determined the following adjustments as stated in the
statutory notice of deficiency:
Because petitioners' adjusted gross income for 1993
exceeded $100,000 respondent reduced petitioners' itemized
deductions in the amount of $624.
The amount claimed by petitioners as advertising expense
on Schedule C2 of their return in the amount of $43,362 was
reduced in the amount of $2,925 because it was determined that
the $2,925 was either a personal expense and/or was not an
ordinary and necessary business expense.
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