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would result if we were to allow all or a portion of such claimed
deductions. (For convenience, we shall sometimes refer collec-
tively to the respective deductions that petitioners are claiming
with respect to Mr. Hopkins’s sole proprietorship and with
respect to Mr. Hopkins’s S Corporation as the deductions at
issue.)
To establish entitlement to the deductions at issue, peti-
tioners rely on, inter alia, Mr. Hopkins’s testimony and certain
documents and a photograph. With respect to the testimony of Mr.
Hopkins, based on our observation of his demeanor, we did not
find him to be credible. In addition, we found Mr. Hopkins’s
testimony to be general, conclusory, vague, and/or uncorroborated
in certain material respects. We shall not rely on Mr. Hopkins’s
testimony to establish entitlement to the deductions at issue.
With respect to the documents and the photograph on which
petitioners rely, we find that those documents and that photo-
graph do not establish entitlement to the deductions at issue.
In support of their position with respect to Mr. Hopkins’s
claimed Schedule C deduction of $67,084, petitioners argue that
it is appropriate under section 162(a) to compare Mr. Hopkins’s
automobile racing expenditures of $67,084 to the amount of gross
sales of Westchem (i.e., approximately $2.5 million) during the
first six months of 1999 that were attributable to the sales
efforts of Mr. Hopkins’s sole proprietorship. In support of
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