Betty J. Shackelford - Page 19

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          expenditure as an advance against Renata's mileage reimbursement.           
          However, as noted above, shortly after making the downpayment for           
          the car, petitioner wrote a check to Renata for $200, which she             
          claimed was for mileage reimbursement.  We are not required to              
          accept petitioner's inconsistent and self-serving testimony as              
          gospel.  Tokarski v. Commissioner, 87 T.C. at 77.  We, therefore,           
          sustain respondent's determination with respect to the automobile           
          expenditures.                                                               
               Petitioner claimed a deduction for a check in the amount of            
          $343.75 made payable to Rich, Fuidge, Morris & Sanbrook.  The only          
          evidence that petitioner offered to substantiate the business               
          purpose for this expenditure was her general statement that the             
          amount was paid for legal fees related to her business.10  We do not        
          think that such a general statement is sufficient "to endow * * *           
          [the expenditure] with a business purpose."  Ferrer v.                      
          Commissioner, 50 T.C. 177, 185 (1968), affd. 409 F.2d 1359 (2d Cir.         
          1969).  Accordingly, the deduction for legal fees is disallowed.            


          10After petitioner testified that Rich, Fuidge, Morris &                    
          Sanbrook was the name of a law firm in Marysville, California,              
          she testified as follows:                                                   
                    Q    And did you pay them $343.75?                                
                    A    Yes.                                                         
                    Q    And was that for business or personal?                       
                    A    It was legal fees.  Business.                                
                    Q    Legal fees related to what?                                  
                    A    Business.                                                    
                    Q    Do you remember specifically what business                   
               aspect it was paid for?                                                
                    A    I--I talked about my business in general.  I                 
               don't recall the specific.                                             



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