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that they related to an escrow account that was opened for a
client. Petitioners produced no records showing which portion of
the bank charges for credit cards related to business or personal
matters, nor did they produce any records to show the nature of
the escrow account and related charges. Petitioners have not
shown that they are entitled to a business deduction for these
bank charges.
The education expenses deducted were paid to Lamson College,
apparently for petitioner Kathleen Turner. Petitioner testified
that he required his wife to take courses that would help her
perform services for the business. Except for petitioner's
testimony at trial, no evidence was produced to show that the
expenditures incurred for education were ordinary and necessary
business expenses of the Registry. Petitioners failed to produce
any documents to show which specific courses were taken or the
nature of the courses, and petitioner Kathleen Turner did not
testify. Petitioners have failed to carry their burden of
showing that respondent's determination is incorrect.
With respect to the disallowance of the deduction for
"dues", petitioners provided copies of checks that appear to be
for various magazines, periodicals, and other publications.
Petitioner testified that some of these checks were for magazines
needed for business purposes. Petitioner testified that a
portion of the amount deducted for "dues" also included
advertisements in at least four magazines and/or periodicals.
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Last modified: May 25, 2011