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ordered to pay under Paragraph 8 of the Final Decree of Divorce
entered on February 8, 1988." The action, therefore, had nothing
to do with any dispute concerning petitioner and the Internal
Revenue Service over petitioner's tax liability, but rather arose
from a debt between petitioner and his former wife that in turn
arose out of the divorce proceedings. As such the legal expenses
incurred were clearly personal and are nondeductible. United
States v. Gilmore, supra.
The remainder of the miscellaneous deductions in dispute
($4,151) are more nebulous. Petitioner appears to argue that at
least part of this amount was for other legal expenses, including
his former wife's attorney's fees incurred in connection with the
litigation described above. For the same reason, these expenses
are not deductible. Petitioner also contends that a part of this
amount was incurred in purchasing or depreciating a computer.
Petitioner, however, offers no substantiation for this expense.
Moreover, it appears that, similar to the printer discussed
infra, section 280F(d)(3)(A) prohibits any deduction.
In sum, except for the allowance of $133,86 for safety
shoes, respondent's determination is sustained with respect to
the deficiency.
Respondent also determined that petitioner was liable for an
accuracy-related penalty for negligence in the preparation and
filing of his return. Section 6662(a) imposes a penalty in the
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