Marcus V. and Polly A. Booker - Page 13

                                       - 12 -                                         
                                             1999                 2000                
          Car and truck                      $ 5,650.00     $ 7,006.00                
               Supplies                 1,242.23            1,267.07                  
               Taxes/licenses                -0-                 360.00               
               Utilities                          -0-            300.00               
               Wages                          113,825.00        9,415.00              
          Total concessions             $20,717.23      $18,348.07                    
               1In addition to the $13,300 claimed by petitioners as a wage           
          expense on their 1999 income tax return, respondent also conceded           
          an additional $525 claimed by petitioners at trial.  See infra              
          note 6.                                                                     

               With respect to supplies, petitioners contended at trial               
          that they were entitled to amounts in addition to those                     
          respondent conceded.  Petitioners, however, presented no                    
          documenting information to support their arguments.  Moreover,              
          some of the purchases claimed, but not substantiated, included              
          computers and a copier, which would be capital assets subject to            
          depreciation.  They also presented receipts and copies of checks            
          purportedly for supplies; however, those records do not satisfy             
          the Court that the amount claimed is in excess of what respondent           
          has conceded.  Additionally, some of the other documentation                
          presented appeared to be for personal expenses, which are not               
          deductible under section 262.5  Petitioners, therefore, have not            
          established their entitlement to a deduction for supplies in                
          excess of the amounts conceded by respondent.                               

               5Petitioners offered into evidence two manila envelopes                
          containing receipts purportedly for supplies.  The envelopes                
          included, however, receipts for beer, milk, underclothes, and               
          nail polish remover, which, without explanation from petitioners,           
          appear to be personal expenses.                                             

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