Claude D. Mayo, Sr. and Lessie M. Mayo - Page 4

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          dividends, pensions, and wages of $61,929 and $60,589,2                     
          respectively.  Petitioners deducted losses of $24,554 in 1995 and           
          $24,729 in 1996 from the used-car activity (Mayo’s Auto Sales).             
          Petitioners’ Schedule C for the years in issue showed the                   
          following:                                                                  
                                        1995                   1996                   
          Gross Income                  $10,530        $11,580                        
          Less:                                                                       
               Insurance      $2,320                   $2,520                         
               Interest       6,311                    5,893                          
               Legal expenses      130                 140                            
               Office expenses     291                 -0-                            
               Repairs        6,450                    230                            
               Supplies       16,310                   -0-                            
               Taxes & licenses    470                 -0-                            
               Utilities      2,802                    -0-                            
               Car & Truck         -0-                 4,464                          
               Wages               -0-                 568                            
               Other expenses      -0-                122,494                         
          Total expenses                 35,084               36,309                  
          Loss                     $24,554                  $24,729                   
               1Other expenses consisted of cleaning supplies ($147), tags            
          and licenses ($360), auto parts ($3,657), State inspection                  
          ($150), car purchases ($15,420), rental uniforms ($780), and                
          office and car phone ($1,980).                                              
               Mayo’s Auto Sales began operations in 1989 or 1990, and has            
          never operated at a profit.  For the taxable years 1993 and 1994,           
          petitioners reported losses of $14,225 and $16,021, respectively,           
          from this activity.  The records of the Virginia Department of              
          Motor Vehicles show that petitioners sold four automobiles during           


          2    The 1996 income also includes gambling income and capital              
          gains.                                                                      




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