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Commissioner, T.C. Memo. 1999-148. Petitioner’s residence was
not his principal place of business. Therefore, he is not
entitled to deduct his commuting expenses.
Petitioner claims on brief, without any citation of the
record, that the “other property lease” amounts represent rent
paid to the landlord for the Burbank office. Respondent allowed
a deduction for all rent paid for use of the Burbank office. It
is apparent that petitioner has not shown what the $11,500 in
claimed “other property lease” expenses was for. Petitioner did
not substantiate his “other property lease” claim.
Petitioner argues on brief that $1,848 should be allowed for
repairs and maintenance. Respondent already allowed this amount.
Petitioner’s presentation to the Court was so disorganized that
petitioner apparently briefed an issue that is not in dispute.
Respondent has allowed deductions for all amounts petitioner
substantiated. Petitioner has presented no credible evidence to
support the allowance of additional deductions. We therefore
uphold respondent’s determination disallowing Schedule C
deductions and cost of goods sold of $278,365.
Airplane Expenses
Petitioner asks the Court to allow him a deduction for
expenses relating to his airplane. Petitioner did not claim
deductions for airplane expenses on his return, nor did he seek
allowance of deductions for airplane expenses in his petition to
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