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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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