Andrew Wesley Frank & Joy Mary Frank - Page 15

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               Petitioners deducted $2,818.54 on their 1992 return for                
          costs associated with their purchase of the Springs Road                    
          property.  They deducted the following as closing costs:                    
               Item                         Amount of Expense                         
               Settlement charges          $2,746.54                                  
               Credit report                         97.00                            
               Lawyer fee                            80.00                            
               Mailing fees                          4.58                             
               Notary fees                           10.00                            
               Recording fees                        30.00                            
               Roofing permit fee                    72.00                            
               Fee to obtain a loan                   300.00                          
               broker's license                                                       
                                      3,340.12                                        
               Petitioners contend that they may deduct those amounts and             
          an additional $521.58.  We disagree.                                        
               Petitioners introduced part of a HUD-1 Form which was not              
          dated and which did not indicate the property to which it                   
          referred except for "400 Springs" written on it.  Petitioners               
          introduced two receipts for certified mail.  The recipient of the           
          mail was Scott Barry (not otherwise identified in the record).              
          The receipt does not show what was mailed.  Petitioners did not             
          show that they had a business purpose relating to the certified             
          mail items.                                                                 
               Petitioners paid $300 to the State of California, Department           
          of Corporations for a loan broker license.  The words "400                  
          Springs" is written on the receipt.  The receipt is dated                   
          February 21, 1992.  Petitioners bought the Springs Road property            
          in August 1992.  We are not convinced that the fee to obtain the            






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