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findings of fact from which the Court could find that the Careys
had proven the expenses claimed on the Carey Schedule C. The
Careys failed to propose such findings. We have reviewed the
Careys’ objections to respondent’s proposed findings of fact,
which objections incorporate references to the data in the two
exhibits (and to other exhibits); and, except in two instances,
the Careys have failed to prove that they are entitled to deduct
expenses in excess of those conceded by respondent. We believe
that they have established rental payments for Sunshine of
$10,000 for 1995, not the $9,000 conceded by respondent, and,
thus, allow them an additional deduction on account of those
payments of $1,000. We also believe that they have established
one rental payment of $1,105.75 on account of equipment rented
from ARJO Credit Corp. Otherwise, the Careys have failed to
carry their burden of proving deductible expenses in excess of
those conceded by respondent.
Except with respect to the $157,891 of expenses conceded by
respondent and the additional $2,105.75 of expenses allowed by
us, we sustain respondent’s disallowance of expenses claimed on
the Carey Schedule C.
4. NOL Carryover
Respondent has disallowed the net operating loss carryover
of $11,311 claimed by the Careys on the Carey 1995 return. The
Careys have failed to prove any facts showing their entitlement
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