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respondent’s administrative file appear consistent with the
disallowance of the Schedule C deductions. Petitioner was unable
or unwilling to articulate the specific documents that were
presented to the IRS and which were not available at trial. We
now consider the specific Schedule C deductions claimed by
petitioners.
2. Interest Deduction
Petitioner asserts that he paid interest on a loan relating
to a tractor purchased during 1999. Petitioner presented
credible testimony and some documentation which established that
he paid at least $1,044 in interest on the loan, which was used
to purchase a tractor for his Schedule C activity. As such,
petitioner is entitled to the claimed interest expense deduction
in full.
3. Repairs and Maintenance
Respondent agreed at trial that petitioners are entitled to
a deduction in the amount of $9,595.12 for this item. This
amount exceeds the amount claimed on the 2001 tax return of
$7,640.
4. Commissions and Fees
Petitioners claimed a deduction in the amount of $16,000 for
this item, representing amounts paid to persons who loaded and
unloaded freight. No documentation or specific testimony was
presented as to the amounts paid to such individuals. While it
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