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($1,314), depreciation ($1,599), fertilizers ($550), insurance
($1,200), supplies purchased ($150), and taxes ($123.52). Of
these amounts, we find substantiation for $39.87 for supplies.5
In addition, we accept Mr. Stukes’s testimony that petitioners
paid $1,200 for farm insurance for 2002. We therefore hold that
these amounts are allowable deductions.
The amounts for custom hire and depreciation were
unsubstantiated. The amounts claimed as deductions for
fertilizers and taxes were also unsubstantiated. As there is no
rational basis upon which we can estimate the amounts of these
expenses, we hold that they are not deductible.
Issue 2. Schedule A Deductions
We now turn to the amount of the excess unreimbursed
employee and other miscellaneous expenses deduction to which
petitioners are entitled. On Schedule A of their 2002 return,
petitioners reported itemized deductions of $72,921. Respondent
disallowed $39,048 of this amount, which consisted of claimed
unreimbursed employee business expenses of $7,930, attorney’s and
accountant’s fees of $32,610, and tax preparation fees of $20,
reduced by 2 percent of petitioners’ adjusted gross income.6
5Petitioners’ mileage records and corresponding bank records
show purchases of supplies on Sept. 3 and Oct. 1.
6See supra note 1.
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