Robert B. and Betty D. Harris - Page 33




                                       - 32 -                                         
               The only evidence presented with respect to miscellaneous              
          expenses of $90.65 consisted of $32 paid to the U.S. Postal                 
          Service and $27.05 to Seessel’s grocery store in Memphis.13  Both           
          checks were signed by petitioner wife and were written on                   
          petitioners’ joint checking account.  The check to Seessel’s                
          contained a notation in the memo section that the purchase was              
          for flowers.  The dues and publications expense consisted of                
          $35.32 paid to Rodale Books.  The shipping and postage expenses             
          consisted of numerous payments to the Postal Service and Mail               
          Boxes, Etc., for various mailing and shipping charges as well as            
          for postage stamps.  At least one shipping charge was from                  
          petitioner to petitioners’ daughter.                                        
               The evidence is insufficient to show that any of these                 
          expenses were ordinary and necessary expenses incurred in the               
          conduct of a trade or business, and, therefore, these expenses              
          are not deductible.                                                         
               On this record, the Court holds that petitioners are not               
          entitled to Schedule C deductions for 1994, 1995, and 1996 in               









               13   Nothing further was submitted with respect to the                 
          remaining amount claimed.                                                   






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