Larry M. Petty and Jean L. Petty - Page 13




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          truck and the trailer.  The only documentary evidence petitioners           
          submitted with respect to the purchase in question was a check              
          dated January 7, 1994 (check), in the amount of $500 that was               
          payable to Bledsoe Ford.  The signature line on that check bore             
          the name “Larry Petty”, and a notation on the check stated:                 
          “down on 93 F350".  Petitioners contend that the check was for              
          the purchase of the extended warranty on the truck and not for              
          the purchase of the truck itself.  On the record before us, we              
          find that petitioners have failed to establish that they paid               
          specified amounts of expenses during their round trip from Alaska           
          to Texas, that any such amounts were paid in 1993, that any such            
          amounts were for ordinary and necessary expenses paid in 1993 in            
          carrying on any trade or business of Mr. Petty or petitioners,              
          and that any such amounts were not already included as part of              
          the expenses conceded by respondent.  We further find on the                
          instant record that petitioners have failed to establish their              
          entitlement for 1993 to any deduction for depreciation under                
          section 167(a) with respect to their purchase in Texas of a truck           
          and a trailer.                                                              
               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 deductions under sections 162(a) and 167(a) in excess           
          of any such deductions conceded by respondent with respect to               
          amounts that they claim they paid during their round trip from              






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