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8. It has not been shown that the $4,500 that Service
deducted for stock purchased in the name of the Johnsons' minor
child was purchased for a business purpose.
9. The $56,000 that Service paid to Linda Krabill, Kent
Oaks, and Ed Rector, claimed as bad debts for 1984, were all
nonbusiness personal loans. It has not been shown that those
loans were uncollectible as of the end of the taxable year
1984. No part of the $56,000 is deductible for the 1984 tax
year.
10. It has not been shown that the legal fees claimed by
Service are allowable in amounts greater than those allowed by
respondent.
11. Service has not shown that it is entitled to the $1,063
deduction for "Seminar Training Program Costs" during 1982.
12. Service has not shown that it is entitled to the
deductions of $2,172, $2,008, and $1,797 claimed for 1982,
1983, and 1984 for "Dues & Subscriptions and Memberships and
Tuitions".
13. Of the $6,891, $8,800, and $7,694 claimed for
"Automobile and Automobile Insurance" for 1982, 1983, and 1984,
Service is entitled to deduct 20 percent of the homeowner's
insurance on the Johnsons' residence and an additional $1,000
each year for auto insurance.
14. Service has not shown that it is entitled to any portion
of the $8,671, $6,276, and $19,264 of the expenses for "Travel
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