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  • -

    19

-

115

(1933).

Petitioner

has

not

es

tablished that he paid more for

kitchen remodeling than the $20,00

  • 0

    respondent

allowed.

He

provided two documents from Frank

and Sal Fricano for material

and labor for “tiling kitchen & fo

yer”.

10

Both

documents

provide

for tiling an area of 305 square f

eet.

The

documents

could

be

estimates rather than invoices, an

d they do not establish that

the work was completed or that the

stated amounts were paid.

Petitioner asserts that he sp

ent several thousand dollars to

add fireplaces to the New Jersey h

ouse.

He

did

not

provide

any

checks or receipts to substantiate

the cost of the fireplaces.

We find that petitioner has n

ot established that the capital

improvements he and Mrs. Wood made

to the New Jersey house

totaled

more

than

$153,435.

We

su

stain respondent’s

determination on this issue.

For the years at issue, petit

ioner reported the following on

the consulting business Schedules

C:

III. Net Profits From Petitioner’s

Consulting Business

1994

1995

1996

Income

$75,657

$53,804

$60,072

Expenses

(51,879)

(27,527)

(42,829)

Expense for business use of

(6,025)

(11,362)

(4,674)

Net profit

17,753

14,915

12,569

10One is clearly is also dated June 5 “85”.

dated “June 5 - 84”.

The second

but

it

appears

the

“84”

has

been

document changed to

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