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E. Travel and Meals and Entertainment Expenses
Petitioners owned rental properties in Indiana, Kentucky,
and Virginia and farmland in Kentucky. The farmland was
inherited from petitioner’s father in 1990.
There are no structures on the farmland except for fences.
Many of petitioner’s family members live near his Kentucky
farmland. His brothers own farmland on either side of his land.
There was no crop grown on or harvested from the farmland in
1993. His farm equipment was stored in his brother’s barn. In
1994, petitioner’s brother raised the tobacco crop grown on the
land, and petitioner and his brother split the expenses and
proceeds from the sale of the crop.
On Schedules C and E, petitioners claimed travel and meals
and entertainment expenses related to visiting their various
properties. Respondent denied petitioners’ deductions on both
schedules for lack of substantiation. Petitioners now claim
additional travel expenses related to Schedule E.
OPINION
Issue 1. Estoppel
As a preliminary matter, petitioners argue that letters sent
to them by respondent after the issuance of the notice of
deficiency indicating that “the amount you now owe” is “none” are
“binding admissions”. Such “binding admissions”, petitioners
believe, are determinative of their case and according to them
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