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of repairs, he purchased the materials himself and hired
individuals to provide the labor.
To substantiate the deduction for 1993, petitioner provided
copies of two checks. One check was for $100 and payable to an
individual, while the other check was for $296.40 and payable to
a building and supply store. To substantiate his deductions for
1994, petitioner provided copies of 26 checks totaling $5,767.43,
all payable to businesses such as Hechinger, Home Depot, and
Providence Lighting. All of these businesses sell goods which
can be used to repair or renovate an office or a personal
residence.19
All the checks were drawn on the same checking account that
petitioner used to pay personal and business expenses. None of
the checks contained any notations identifying their intended
purpose, and petitioner did not provide any invoices from the
persons who did the repair work. In the case of taxable year
1994, petitioner did not indicate what his cost of labor was or
provide a check payable to a contractor or individual for the
repair work allegedly done.
In short, we cannot tell from the record whether petitioner
bought several fixtures for his new home or whether he in fact
repaired one of his offices. Petitioner has not met his burden
19Petitioner testified that he had some renovation work done
on his Pennsauken, New Jersey, office in 1993.
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