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identified petitioner as the proprietor of a business, one named
“G.F. de Ban� Publishing” and the other “Grandfather Time Antique
Clocks”. The checks were written for a variety of expenses,
including mortgage, telephone, water, waste, credit card,
insurance, department of motor vehicles, and taxes. Both
accounts were used alternately for some of the same payees. It
appears that these were used by petitioners as nothing more than
personal banking accounts. Neither the existence of these
accounts nor petitioner’s testimony establishes the existence of
any business.
Even if the record established the existence of a trade or
business, it does not show that the deductions claimed were for
ordinary and necessary business expenses. In addition to the
checks mentioned above, petitioners provided credit card
statements to substantiate the expenses. Notations were made
beside some of the charges, and petitioners, in preparation for
trial, summarized some of the charges and checks as belonging to
certain categories of expenses. From the evidence before the
Court, it appears that, for the most part, petitioner simply
scoured the credit card statements and canceled checks in search
of expenses which could be matched to the amounts on the returns.
For example, with respect to the bad debt expenses of $15,
petitioner testified that: “I find when I was examining all of
the receipts that I have from the charge card, from the two
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Last modified: May 25, 2011