Oscar R. Contreras - Page 16

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          period February 5 through March 5, 2001; two monthly statements             
          for a First Tennessee Bank Visa card covering the period March 5            
          through May 7, 2001; and two monthly statements for a MBNA                  
          America Visa card covering the periods May 8 through June 7,                
          2001, and November 8 through December 7, 2001.  (We shall refer             
          collectively to all of the above-described statements as peti-              
          tioner’s credit card statements.)                                           
               Petitioner did not testify about any of petitioner’s credit            
          card statements.  Petitioner does not indicate on brief, and we             
          have no way of knowing, whether he is claiming all of the ex-               
          penses shown in those statements.9  There is no notation on any             
          of petitioner’s credit card statements indicating which, if any,            
          of the expenses listed in those statements petitioner is claiming           
          here.10                                                                     
               On the instant record, we have no way of knowing (1) which,            
          if any, of the expenses listed in petitioner’s credit card                  
          statements petitioner is claiming in this case or (2) the issue             
          presented to which any such expense pertains.  In addition,                 


               9We note that the total amount of expenses shown in peti-              
          tioner’s credit card statements exceeds the total amount of                 
          expenses that petitioner claimed in petitioner’s Form 2106,                 
          restaurant Schedule C, and PDA consulting Schedule C.                       
               10Several of petitioner’s credit card statements have a                
          notation adjacent to each of the expenses listed, such as a tick            
          mark, a check mark, or an underlining or circling of an amount.             
          We presume that petitioner made those notations as he was review-           
          ing those several statements in order to note that he had veri-             
          fied the accuracy of each expense listed in those statements.               




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