Terry U. Neal - Page 15




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          consisting of $790 for car and truck expenses, $1,256 for                   
          telephone expenses, and $23 for storage expenses.                           
               Petitioner presented no documentary evidence to show he                
          actually incurred any of the aforementioned expenses disallowed             
          by respondent.  See Niedringhaus v. Commissioner, supra; Tokarski           
          v. Commissioner, supra.  Moreover, the Court is not convinced               
          that petitioner incurred any trade or business expenses in excess           
          of those allowed by respondent.  Consequently, on this record,              
          the Court holds that petitioner is not entitled to any trade or             
          business expense deductions for 1994 in excess of those allowed             
          by respondent.  Respondent, therefore, is sustained on this                 
          issue.                                                                      


                                                 Decision will be entered            
                                             under Rule 155.                          





















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