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and $14,951 in 1990.6 Petitioner contends that he is entitled to
these deductions under section 162(a).
Petitioner failed to introduce any documentary evidence to
support these claimed deductions. Because petitioner has failed
to substantiate these amounts and we are not convinced that he
actually paid any of the disallowed wage expenses, we find that
petitioner is not entitled to deductions for wages of $3,210 for
1989 and $14,951 for 1990.
C. Beauty Shop and Horse Racing Activities
Petitioner claims that he is entitled to additional
deductions for unreported business expenses paid in the beauty
shop and the horse racing businesses during the years in issue.
Respondent contends that petitioner has failed to substantiate
the amounts of additional business expenses.
Petitioner offered no credible evidence for computing
additional beauty shop and horse racing expenses paid in the
years in issue. In support of these additional deductions,
petitioner offered into evidence a handwritten schedule that he
prepared, apparently for purposes of this trial, which lists the
horse trainer costs. Petitioner was not a credible witness. He
6 On their 1989 and 1990 Federal income tax returns,
petitioner and Ms. McNamara claimed deductions of $86,580 and
$90,101, respectively, as beauty salon wages. In the notice of
deficiency, respondent disallowed only portions of the deductions
for which petitioner and Ms. McNamara failed to provide
substantiation.
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