- 19 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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