Frank de Bane and Kathleen Naber-de Bane - Page 8

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          to the IRS in 1997.  However, an earlier letter, sent in 1998,              
          made no mention of missing records but stated petitioner would              
          “come forward with all requested documents and other business               
          records” upon audit of his return.                                          
               Based on the record, we cannot find that any of the expenses           
          listed on the return were ordinary and necessary in carrying on a           
          trade or business.  We therefore sustain respondent’s                       
          disallowance of the business expense deductions.                            
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               

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