Robert J. & Shari L. Hartz - Page 12




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          and are not reflected in the notice of deficiency.  The only item           
          appearing on the amended return form which petitioner chose to              
          pursue at trial was a claim for an additional deduction for                 
          business interest expense of $1,487.  Petitioner testified that             
          the expense was incurred in connection with vehicles used for               
          business purposes.  Petitioner, however, provided no reliable               
          substantiation that he incurred this expense in this amount or              
          that the expense had a business purpose.  Consequently,                     
          petitioner is not entitled to an additional business expense                
          deduction for 1995.  Sec. 6001; sec. 1.6001-1(a), (e), Income Tax           
          Regs.                                                                       
          Loss on Disposition of Business Property                                    
               On October 10, 1995, petitioner and Jeanie L. Melson (Ms.              
          Melson) jointly entered into an installment contract to purchase            
          a 1995 Winnebago.  The contract indicated that the Winnebago was            
          to be used primarily for personal, family, or household use.  The           
          purchase price of the Winnebago was $65,613.  After applying a              
          downpayment and incurring various costs and fees, the total                 
          principal amount financed under the contract was $62,848.                   
          Approximately 10 to 15 days after its purchase, Ms. Melson took             
          the Winnebago from petitioner’s possession.  The bank which                 
          financed the purchase of the Winnebago sued petitioner for                  
          amounts due with respect thereto in 1996 and repossessed the                
          vehicle from Ms. Melson in 1997.  Petitioners claimed a deduction           






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