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Before the trial in this case commenced, petitioner again
produced for review by respondent’s employees, including a
revenue agent and an Appeals officer, voluminous records in
support of the Schedule C deductions claimed on her returns for
the years at issue. Respondent’s review of petitioner’s records
resulted in the preparation of itemized lists of some of
petitioner’s canceled checks, credit card expenditures, and
receipts. The lists were revised on several occasions and
admitted into evidence during trial. The lists were prepared
without any reference to the categorization of expenses claimed
on petitioner’s Schedules C for the years at issue because
respondent claimed that he could not tell how petitioner’s
expenses were grouped for reporting purposes on petitioner’s
returns.
At the beginning of trial, respondent conceded that
petitioner had deductible Schedule C expenses for the years at
issue in the following amounts:
Year Amount Exhibit No.
1987 1$50,184.70 38-R
1988 64,442.41 39-R
1989 77,162.01 40-R
1990 73,632.74 41-R
1Respondent used a subtotal ($11,144.18) instead of the
total ($12,034.71) from Sec. B of Ex. 38-R in calculating the
amount of Schedule C expenses he conceded for 1987 ($49,294.17).
Following trial, respondent conceded additional Schedule C
deductions for each of the years at issue as follows:
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