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examination of petitioner’s business records for those years
appears unwarranted and arbitrary.
As arbitrary as respondent’s blanket disallowance of
petitioner’s Schedule C expenses for 3 of the 4 years at issue
appears on these facts, however, it is nevertheless clear under
our jurisprudence and that of the Court of Appeals for the Eighth
Circuit that petitioner bears the burden of proof as to her
deductions. We are obligated to analyze the evidentiary record
and to weigh the evidence in order to decide if petitioner has
carried her burden of persuading this Court that respondent’s
disallowance of her Schedule C deductions for the years at issue
was erroneous and/or arbitrary. See Oliver v. Commissioner, 364
F.2d 575, 577 (8th Cir. 1966), affg. T.C. Memo. 1965-83.
The record in this case establishes that petitioner
maintained an active law practice during the years at issue. In
connection with that law practice, petitioner paid business
expenses that were categorized and deducted on her Schedules C as
advertising, car and truck, depreciation/section 179, employee
benefits, insurance, interest, legal and professional, rent,
supplies, taxes, travel, meals and entertainment, utilities,
wages, dues and subscriptions, process services, contract
services, court fees, collection fees, bank charges, and
miscellaneous expenses. With the assistance of Mr. Aunan’s
workpapers, we were able to ascertain, to a large extent, how
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