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expenses underlying the denied deductions were either personal in
nature, or inadequately substantiated. On the other hand, in a
2-page document entitled "The Audit of '91", by Pennel P. Irwin,
petitioner states in part:
Because of the nature of the business, expenses vary
depending upon the type of writing being done. For
non-fiction writing, expenses are limited to just those
items directly related to the subject being researched.
For fiction writing all personal experiences and
observations are all business experiences and
observations * * * so there is no distinction between
personal and business costs * * *. (Example: Upon
awaking in the morning the toiletry and dressing
process carried out by myself, and observed in others,
is research whose end observations are included in the
fictional writing for similar actions carried on by the
various characters; and therefore, different grooming
products would be justifiable research expenses as well
as different clothing that conveys fit and feel * * *.)
Thus all expenses I incur are either for business
research or business maintenance or business
production, though I have, out of choice, not declared
all of these---such as food, clothing, toiletries or
amusements.
In an attempt to substantiate his claimed deductions, petitioner
provided copies of canceled checks, drawn on his personal
account. Petitioner, however, failed to indicate the precise
nature of the expenses underlying many of the checks. For
example, petitioner lists many of the expenses under the broad
rubric, "research materials", without specifying the expenditure
in any detail.
During the course of the examination of petitioner's return,
respondent sought certain materials, including a log or diary to
amounts of $101 in 1991 and $172 in 1992, attributable to the
costs of a computer disk drive and a cabinet.
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