Walter L. Medlin - Page 15

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          petitioner prepared for the deposits and disbursements from his             
          personal bank accounts.  Petitioner’s spreadsheets classified the           
          various disbursements as expenditures for automobiles, dues and             
          subscriptions, office, telephone, utilities, interest,                      
          maintenance and repair, travel and entertainment, licenses and              
          taxes, commissions paid, insurance, and miscellaneous.  Those               
          disbursements were then claimed on the Schedules C as deductions            
          from the gross income he reported for his real estate business.             
          Respondent reconstructed petitioner’s expenses from buying and              
          selling real estate for 1985 through 1988.  See appendix A.  In             
          reconstructing petitioner’s expenses, respondent disallowed many            
          of the deductions petitioner claimed for a failure to                       
          substantiate or a failure to show an ordinary and necessary                 
          business expense for purposes of section 162.  Respondent allowed           
          deductions for petitioner’s real estate business in much larger             
          amounts than petitioner originally claimed on his returns.65                
                                       OPINION                                        
               Petitioner did not present any evidence that respondent                
          erred in reconstructing his Schedules C real estate expenses.               
          Petitioner does not present any arguments on brief relating to              
          his Schedules C real estate expenses or respondent’s                        


               65Of course, it is likely that many of these expenses were             
          related to properties that petitioner sold but failed to report.            
          We point out that the largest items of additional expense                   
          deductions are interest and taxes which appear to be linked to              
          properties which petitioner sold as part of his real estate                 
          business.                                                                   




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