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trucking/hauling business he operated as a sole proprietorship
during each of the years at issue.
Respondent audited petitioner’s Federal income tax returns
for 1992, 1993, and 1994. By notice of deficiency dated January
26, 1998, respondent determined that the following adjustments to
petitioner’s Schedule C expenses were required:
1992 1993 1994
Car & truck $4,170 $5,109 --
Depreciation (1,630) (2,609) ($4,145)
Drivers exp. -- -- 2,522
Fuel 2,601 242 4,528
Insurance 170 498 (29)
Legal (85) (148) (167)
Meals 2,329 1,642 1,021
Plates & comp. (1,132) -- 813
Repairs 8,276 4,748 12,041
Tires -- (2,644) (203)
Utilities -- -- 434
Self-employ. (1,038) (1,099) (1,187)
Respondent also determined that petitioner had additional gross
receipts of $8,717 for 1993 and unreported interest income of
$125 for 1994 and that petitioner was liable for the accuracy-
related penalty in each of the years in issue.
Petitioner conceded, or does not dispute, the adjustments to
gross income, insurance, legal, license plates and compensation,
and tires. The adjustment concerning interest income is deemed
conceded because petitioner offered no evidence concerning the
adjustment.
On brief, respondent conceded the driver expense adjustment
for 1994 and portions of the meal and repair expense adjustments
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