Frank H. and Marla C. Black - Page 14




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               Petitioners never provided Agent Helton with any canceled              
          checks or any other credible evidence to show that they had made            
          any contributions to NFBC (or any church) during 1987, 1988, or             
          1989.                                                                       
               During May 1991, Mrs. Black purchased a new Magic-Chef                 
          electric range at Appliance and Furniture World in Charlotte,               
          North Carolina.  The range was installed in petitioners’ kitchen,           
          was used to cook meals for petitioners’ family and their guests,            
          and it was not used for any business purposes.  Mr. Black                   
          deducted the $839.95 paid for the electric range as “Supplies” on           
          the Schedule C attached to the 1991 joint return.                           
               During February, 1991, petitioners paid $929.10 to Steve               
          Starnes, d.b.a. Steve’s Upholstery, for replacing the foam and              
          re-upholstering a sectional sofa.  The sofa was kept in the den             
          in petitioners’ home, which was used on a regular basis as a                
          family room by petitioners and their children and was not devoted           
          exclusively to business purposes.  Mr. Black deducted the $929.10           
          paid for the sofa re-upholstery as “Supplies” on the Schedule C             
          attached to the 1991 joint return.                                          
               During May 1991, Mrs. Black purchased a 75-gallon salt water           
          aquarium from Kent Drum (Mr. Drum), the owner of K&M Pet Center.            
          The aquarium and related equipment were delivered to petitioners’           
          house on the evening of May 29, 1991, and left unassembled in               
          their den.  The next day Mr. Drum assembled the aquarium in                 







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