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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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