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Respondent determined deficiencies in petitioners’ Federal
income taxes for 1997 and 1998 in the amounts of $4,105 and
$3,514, respectively.
The issues for decision are as follows:
(1) Whether petitioners are entitled to Schedule C
deductions for “Car and truck expenses” for 1997 and 1998. We
hold that petitioners are not.
(2) Whether petitioners are entitled to Schedule C
deductions for “Employee benefit programs” for 1997 and 1998. We
hold that petitioners are not.
(3) Whether petitioners are entitled to a Schedule C
deduction for “Insurance” for 1997. We hold that petitioners are
not.
Background
Some of the facts have been stipulated, and they are so
found.
Petitioners resided in Wilmington, Massachusetts, at the
time that their petition was filed.
For the sake of convenience, we shall hereinafter refer to
petitioner Wayne Robert Rogers as petitioner.
A. Petitioner’s Business as a Computer Consultant
Petitioner has worked as a self-employed computer consultant
for many years. During 1997 and 1998, the years in issue,
petitioner had a single client, Bainbridge International, Inc.
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