James W. Taylor - Page 9




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          transportation is also listed property under section                        
          280F(d)(4)(A)(ii).                                                          
               Petitioner also testified that the depreciation deduction              
          claimed on his 1993 Federal income tax return was by mistake                
          misclassified and that the expenditure actually was in the nature           
          of a rental expense.                                                        
               We are not persuaded by petitioner's testimony or by the               
          evidence he presented regarding his claim for a rental expense              
          deduction.  Petitioner asserts that during 1993 he paid $3,500 to           
          rent a raft, with boat gear and oarsmen, for use in his video               
          business.  To substantiate his claimed rental expense, petitioner           
          introduced a handwritten receipt.  Petitioner failed to provide             
          any further testimony regarding these items.  The receipt                   
          presented by petitioner is not persuasive.  The person who                  
          allegedly wrote the receipt was not available at trial.  Under              
          these circumstances, and in view of petitioner's failure to                 
          provide substantiating detail, we are not convinced that                    
          petitioner paid $3,500 to rent a raft, with boat gear and                   
          oarsmen.  Based upon the foregoing, we hold that petitioner has             
          failed to substantiate his claimed entitlement to a depreciation            
          or rental deduction.                                                        
               After considering the other receipts petitioner presented,             
          we find that, with one exception, petitioner has failed to                  
          demonstrate that he is entitled to the Schedule C deductions                
          claimed on his 1993 Federal income tax return in excess of                  




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