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petitioners have failed to establish that during 1993 they paid
more than $183.59 of the claimed Schedule C expenses for “Repair
parts” that are at issue. We further find on the record before
us that petitioners have failed to establish that the $2,688 of
Schedule C expenses at issue claimed as deductions for 1993 for
“Repair parts” are ordinary and necessary expenses paid during
that year in carrying on Mr. Petty’s truck service business.
Based on our examination of the entire record before us, we
find that petitioners have failed to prove that they are entitled
for 1993 to deduct under section 162(a) $2,688 of their claimed
Schedule C expenses for “Repair parts” that remain at issue or
any other amount in excess of that conceded by respondent.
With respect to the deductions for 1993 totaling $3,748
claimed in Schedule C for “Repairs and maintenance”, respondent
concedes that petitioners are entitled to deduct $865 of those
claimed expenses. However, respondent contends that petitioners
are not entitled to deduct the balance (i.e., $2,883) of those
claimed Schedule C expenses because they have not shown that such
expenses are ordinary and necessary expenses paid during 1993 in
carrying on Mr. Petty’s truck service business. On the record
before us, we agree with respondent.
We note initially that the documentary evidence on which
6(...continued)
example, two such claimed paid expenses are for keys and one such
claimed expense is for a membership fee in a tax association.
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