Mary T. King and Fatai O. King - Page 20




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                  Petitioners claim a deduction in the amount of $956                   
             described on their amended return as “United News/Septa-                   
             payment”.  In support thereof, they rely on two checks, one                
             drawn to the order of United News (Levy) in the amount of                  
             $300, and the second drawn to the order of Septa in the                    
             amount of $656.25.  Respondent conceded the deductibility                  
             of those payments at trial.                                                
                  Petitioners claim a deduction for $520 attributable to                
             the cash payments allegedly given to a cleaning woman “to                  
             clean the place”.  In support of their claim, petitioner                   
             introduced a handwritten sheet purporting to show 26 cash                  
             payments totaling $560.  There are 20 payments of $20, 4                   
             payments of $25, and 2 payments of $30.  The ledger sheet                  
             identifies the cleaning woman as “Gloria Ashers”.  In his                  
             testimony, petitioner said:  “I pay her $20, $10 sometime,                 
             and I have the record that I wrote down.”  He identified                   
             the cleaning woman as Gloria Lashley, “L-A-S-H-L-E-Y-.”                    
             When petitioner was asked what the cleaning woman cleaned,                 
             he replied:  “The front because the place is dirty, because                
             people come, they drink, they throw bottle, they break it.                 
             So I have to pay for that because when the Street Depart-                  
             ment come they give me citation before.”  Petitioner’s                     
             testimony is vague, and we find that petitioners have not                  








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