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receipts for the shipment that were filled out by
petitioner on United Parcel Service forms and a Damage
Tracer Copy that was issued by UPS, fail to show that any
part of the shipment was lost. To the contrary, according
to a handwritten phone message, a representative of UPS
telephoned petitioner and stated that all seven boxes of
the shipment had been delivered. The only formal
communication from UPS concerning this shipment is the
Damage Tracer Copy which states that petitioner had
reported damage to a "Panasonic EASA Phone". There is no
document from UPS to substantiate petitioner's assertion
that "two bags" were lost and never recovered.
A. Refunds to Clients and Unreimbursed Payments to the
Internal Revenue Service and to State Tax Authorities
As shown in the above schedules, petitioner claims
offsets to gross receipts or deductions under section 162
for the aggregate amounts of direct payments in 1989 and
1990. For 1989, petitioner claims offsets or deductions in
the form of direct payments totaling $113,317.83, including
the $53,643 payment to Hackett and Co., sometimes referred
to as Habsco, that was allowed by respondent, and for 1990
he claims offsets or deductions in the form of direct
payments in the aggregate amount of $81,669.93. In his
posttrial briefs, petitioner asserts that he made the
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