- -22
Gilmore, supra; Caruso v. United States, 236 F. Supp. 88 (D.N.J.
1964). Respondent, however, argues that petitioner has not
substantiated the entire amount of the claimed deduction.
Petitioner introduced into evidence 24 checks that he
claimed represent legal fees and expenses relating to
unemployment compensation litigation. Respondent concedes that
20 of the checks represent deductible amounts totaling $4,396.75.
One of the remaining checks received in evidence is in the amount
of $300 payable to "Richard Stegman Esq." for "consultation", and
two of such checks are payable to "Neil Paulson" in the total
amount of $830. Petitioner offered no evidence that either Mr.
Stegman or Mr. Paulson worked on the unemployment compensation
litigation, and neither person appeared on any court documents
relating to this litigation. The fourth check received in
evidence is a check in the amount of $15 payable to Accurate
Professional Typists. Petitioner could not remember whether this
check was related to the unemployment compensation litigation.
There were also received in evidence two airline passenger
receipts that petitioner claims relate to the unemployment
compensation litigation. The travel represented by the airline
receipts was to Huntsville, Alabama, and occurred over weekends
and holidays. There is a strong indication from these facts that
the travel was for personal purposes. Petitioner claims that car
rental agreements received in evidence represent expenses related
to the unemployment compensation litigation. Petitioner has not
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