- 17 -
For the above reasons, we agree with respondent's
determination regarding the remaining 1989 and 1990 travel
expense items.
d. Contract Labor
Findings of Fact and Opinion
Petitioner claimed deductions for "contract labor", that is,
for secretarial help and other assistance, for each of the three
years at issue. The amounts petitioner claimed, the amounts
respondent allowed, and the amounts respondent adjusted are as
follows:
1988 1989 1990
Per return12 $-0- $17,921 $20,992
Per exam -0- 10,720 17,474
Adjustment -0- 7,201 3,518
Respondent states on brief that petitioner was allowed a
deduction for those people for whom petitioner filed Forms 1099.
The $7,201 adjustment for 1989 consists of the following:
Payee Amount
Joseph Clare $1,355
Gina Cagampan 3,110
Shelly Jue 1,059
Patrick Marason 800
Miscellaneous 877
Total 7,201
The 1990 adjustment consists of the following:
Payee Amount
Marilyn Yee $420
Patrick Marason 508
12 We have reduced these numbers by the amount of the contract labor
expenses dealt with under travel expenses.
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