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petitioners rely to establish their entitlement to deduct for
1993 the expenses remaining at issue that they claimed in Sched-
ule C for “Repairs and maintenance” shows that they paid amounts
during 1993 totaling $5,020.68. However, petitioners claimed a
deduction in Schedule C for “Repairs and maintenance” of only
$3,748, of which, as noted above, respondent conceded $865 at
trial, leaving only $2,883 which remains at issue. Furthermore,
the documentary evidence on which petitioners rely to support
their entitlement to deduct for 1993 the $2,883 of claimed
Schedule C expenses for “Repairs and maintenance” that remain at
issue included a number of checks which do not even involve or
relate to repair and/or maintenance expenses.7 On the instant
record, we find that petitioners have failed to establish that
the entire amount of $5,020.68 that the record establishes they
paid during 1993 relates to “Repairs and maintenance”. We
further find on the record before us that petitioners have failed
to prove that such paid amounts are ordinary and necessary
expenses paid during 1993 in carrying on Mr. Petty’s truck
7For example, three of the checks petitioners introduced
into evidence to substantiate their claimed Schedule C expenses
for “Repairs and maintenance” represent amounts paid for car
titles and registrations; two of such checks represent amounts
paid for ads; and four of such checks represent amounts paid for
items not established by the record. In this connection, Mr.
Petty indicated at trial that a number of the checks introduced
by petitioners with respect to the deductions claimed in Schedule
C for “Repairs and maintenance” represented “a bunch of checks as
an afterthought, that I put in here.”
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Last modified: May 25, 2011