- 6 -
v. du Pont, 308 U.S. 488, 494 (1940). We also note that
petitioner may face other bars to deductibility; for instance,
substantiation. It appears as if an automobile mileage log
allegedly prepared contemporaneously with petitioner's business
travel was actually prepared in preparation for litigation.
Accordingly, we hold for respondent with respect to the
deductions for unreimbursed employee business expenses.
Petitioner failed to introduce any evidence to show that he
renewed a real estate license in 1991, and there is no basis upon
which we can sustain a deduction for this expense.
Petitioner failed to substantiate the amount expended for
tax return preparation fees during 1991. A bill from the
accounting firm of Cherry, Bekaert & Holland indicated that
petitioner spent $599 during 1990 for the preparation of his 1989
tax return. Petitioner's 1990 tax return indicates that Cherry,
Bekaert & Holland also prepared this return. The return is
complicated and voluminous. Accordingly, it appears certain that
petitioner incurred tax preparation fees in 1991, and we allow
petitioner a deduction on his 1991 Federal income tax return in
the amount of $450 for tax return preparation fees. See Cohan v.
Commissioner, 39 F.2d 540 (2d Cir. 1930).
Charitable Contribution Deductions
Petitioner has been active in the Greek Orthodox Church for
many years. He served on the local parish board and later on the
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