Perry H. Kay, Sr. - Page 14

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          with the Oak Village Middle School.  Further, petitioner only               
          selected the middle school option when asked to select the                  
          appropriate options that applied to the applicant.                          
               Petitioner unequivocally completed both applications as an             
          educator, making no mention whatsoever of PK Production.                    
          Petitioner testified that he had a choice of associating himself            
          with the school or PK Production when completing the                        
          applications, yet petitioner chose to affiliate himself with the            
          school on both occasions.                                                   
               It appears to the Court that from the evidence presented               
          that petitioner attended both San Antonio, Texas, conventions               
          primarily in his capacity as an assistant band director.  The               
          record is clear that petitioner has failed to establish that the            
          expenses associated with the San Antonio, Texas, conventions                
          claimed on Schedule C were ordinary and necessary expenses                  
          directly related to PK Production.  See sec. 162(a); sec. 1.162-            
          1(a), Income Tax Regs.                                                      
               Petitioner presented absolutely no evidence, either                    
          documentary or testimonial, to substantiate the additional $65.06           
          of expenses claimed as music educator and professional convention           
          expenses.  Petitioner is not entitled to a deduction for business           
          expenses that are completely unsubstantiated.  Ronnen v.                    
          Commissioner, supra.                                                        
               Therefore, petitioner is not entitled to a Schedule C                  

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