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client's progress in a rehabilitation program at a brain damage
facility in Bakersfield. This testimony was corroborated in part
by the testimony of Kathryn Talley, petitioner's office manager.
Moreover, Renata's trip to Bakersfield was only for the day. We
hold that petitioner has sufficiently substantiated the business
purpose for this expenditure and, therefore, allow a deduction for
it.11
Petitioner claimed a deduction in the amount of $193.31 for
automobile expenses, with respect to the vehicle that petitioner
used in her business. The only evidence introduced to substantiate
this expenditure was a charge statement showing a payment to Toyota
of Sacramento. There is no evidence as to the business purpose of
the charge. Nor is there any evidence as to the amount of time
petitioner used her automobile for business purposes, other than
her vague testimony that she used it "constantly" for business
purposes. Accordingly, we sustain respondent's disallowance of a
deduction for this expenditure.
On October 19, 1989, petitioner and Mr. Maynard traveled to
Guatemala. Petitioner testified that the purpose of the trip was
to improve her Spanish and to become more familiar with Guatemala
so that she could place clients there. Petitioner further
testified that Mr. Maynard accompanied her as a business
11Petitioner appears to have deducted this expense twice--
once as a travel expense and once as cost of goods sold. We
direct the parties to adjust for this in the Rule 155
computation.
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