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inter alia, car and truck expenses of $5,050 and legal and
professional services of $13,870.
In the statutory notice of deficiency, respondent disallowed
the deduction for the employment agency fees because petitioners
failed to show the expense was paid during the taxable year and
that the expense was an ordinary and necessary business expense.
As a result, petitioners’ remaining itemized deductions are less
than the standard deduction of $6,900, which respondent
accordingly allowed in lieu thereof. Respondent also disallowed
petitioners’ Schedule C business deductions listed above because
petitioners failed to show that they were eligible for them.
On January 7, 2000, after the filing of the petition and the
answer in this case, respondent served on counsel for petitioners
requests for admissions. The requests set forth the following
relevant matters:
5. The correct amount of petitioners’ miscellaneous
itemized deductions for 1997 was zero ($0.00) as determined
by respondent.
15. The correct amount of petitioners’ Schedule C
car/truck expense for 1997 was zero ($0.00) as determined by
respondent.
20. The correct amount of petitioners’ Schedule C
legal/professional expense for 1997 was zero ($0.00) as
determined by respondent.
Petitioners never filed answers to the requests for admissions
with the Court as required by Rule 90(c), and according to
respondent’s undisputed assertion petitioners did not serve such
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