Charles Shaw - Page 19

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          determined in the amounts of $199,073 in 1993, $213,564 in 1994,            
          and $166,142 in 1995.                                                       
               3.   Petitioner’s Business Expense Deductions                          
               Petitioner contends that he may deduct greater amounts for             
          business expenses than respondent allowed.  We disagree for                 
          reasons discussed below.                                                    
                    a.   Insurance                                                    
               Petitioner contends that he may deduct insurance expenses of           
          $2,803.25 in 1994 and $2,280 in 1995.  There are four canceled              
          checks in evidence written by petitioner to insurance companies             
          in 1994 and 1995.  However, there is no evidence that these                 
          payments were for petitioner’s business.                                    
                    b.   Supplies                                                     
               Petitioner contends that three checks that he wrote to Sam’s           
          Club, Home Supplies, and Jefferson Variety Store, Inc., were                
          business expenses.  However, there is no evidence that these                
          payments were for business expenses.                                        
                    c.   Travel                                                       
               The parties stipulated that petitioner incurred business-              
          related travel expenses of $4,188 in 1994.  There is no evidence            
          showing the amount of petitioner’s travel expenses for 1993 or              
          1995.  Petitioner contends that he may deduct expenses that he              
          and Ms. Shaw incurred to attend a festival of rural craftsmen in            
          China in each year in issue.  However, there is no evidence                 






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