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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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