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documentation is insufficient to substantiate the claimed
expenses. See Hradesky v. Commissioner, supra at 90.
Petitioner testified that she and her sisters used
petitioner's automobile for both Special Occasions and Special O.
In addition, petitioner admitted that she also used her
automobile on behalf of other businesses, as well as for personal
use. Petitioner failed to establish the percentage of personal
automobile use versus business automobile use.7 Under such
circumstances, any attempt on the part of this Court to estimate
petitioner's purported automobile expenses would amount to little
more than guesswork.
On the basis of the record, we find that petitioner has
failed to establish that either Special Occasions or Special O
incurred any deductible automobile expenses for the years in
issue. Additionally, we find that petitioner has failed to
establish any amount of automobile expenses for the years in
issue and is therefore not entitled to treat such purported
expenses as capital contributions.
The parties stipulated that petitioner had a zero basis in
Special Occasions as of January 1, 1992. Because Special
Occasions did not maintain written records which were accurate
enough to determine petitioner's bases for the 1991, 1992, and
7 Additionally, petitioner failed to establish what percentage
of business use reflects use of the automobile on behalf of
Special Occasions, Special O, Klyce, or Sweets.
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