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expenditures, many of which appear to reflect significant
elements of personal consumption. Even if we were to assume,
arguendo, that some of these expenditures were for items used
aboard petitioner’s aircraft, this fact would not in and of
itself substantiate business purpose, for as previously
discussed, in the criminal investigation petitioner admitted that
he used his aircraft for personal purposes. Even if we were to
assume, arguendo, that some of these expenditures were for
legitimate business purposes, the evidentiary record does not
provide a rational basis for identifying or estimating such
expenditures to the exclusion of the personal expenditures that
we believe are included in these unagreed expenses.
Petitioner has failed to establish entitlement to deductions
he claims for supplies.
5. Labor Expenses
Petitioner seeks to deduct as business expenses two checks
totaling $306 drawn on Romer & Co.’s checking account and made
payable to “Jennie Sheffers” (Sheffers). Petitioner contends
that he gave the checks to Sheffers as payment for washing and
waxing his aircraft. The checks themselves do not have any
notation as to why they were made payable to Sheffers. Besides
petitioner’s own self-serving testimony, we have no corroborative
evidence as to why these checks were drawn. We find it telling
that these checks were drawn on Romer & Co.’s checking account
rather than on the checking account set up for petitioner’s
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