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sioner, 877 F.2d 624, 631-632 (7th Cir. 1989), affg. T.C. Memo.
1987-295; Geiger v. Commissioner, 440 F.2d 688, 689-690 (9th Cir.
1971), affg. per curiam T.C. Memo. 1969-159; Tokarski v. Commis-
sioner, 87 T.C. 74, 77 (1986).
As for the documentary evidence on which petitioners rely,
some of that evidence establishes that petitioners paid certain
amounts for various expenditures.5 However, we find that that
documentary evidence does not show that any of those paid amounts
is deductible for 1993.
On brief, respondent concedes that during 1993 Mr. Petty
operated a truck service Schedule C business. However, respon-
dent contends on brief that petitioners have failed to establish
their entitlement for 1993 to the claimed Schedule C deductions
at issue.
Section 162(a) generally allows a deduction for ordinary and
necessary expenses paid during the taxable year in carrying on a
trade or business. The determination of whether an expenditure
5Not all of the documentary evidence on which petitioners
rely establishes that petitioners paid the expenditures to which
that evidence relates. For example, petitioners introduced
carbon copies of the front, and not the back, of certain checks.
By way of further illustration of documentary evidence on which
we are unwilling to rely is a check that was endorsed on the back
by the payee and immediately thereunder reendorsed by Mr. Petty.
Under Mr. Petty’s endorsement appears petitioners’ bank account
number. Finally, the documentary evidence proffered by petition-
ers included certain invoices which do not indicate that the
sales described in such invoices were made to, and paid by,
petitioners.
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