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At trial, petitioner conceded that although he used the
credit cards for both personal and business purposes, he used
them for personal purposes only in emergencies when he was
"caught without money." Petitioner also testified that he had
four other personal credit cards. Petitioner estimated that he
used the credit cards in issue approximately 75 percent for
business and 25 percent for personal purposes. He made this
estimate based on the business and personal charges that appeared
on the monthly credit card statements.
We find petitioner's estimate of 25-percent personal use to
be reasonable. Accordingly, we allow petitioner to deduct 75
percent of the annual membership fees incurred for 1991 and 1992.
Cohan v. Commissioner, supra.
D. Home Office Expenses
For 1991, petitioner deducted home office expenses of
$1,444, for a facsimile machine, a facsimile stand, a telephone,
and chairs. For 1992, petitioner deducted home office expenses
of $3,385, for chairs, a desk lamp, a computer desk, a computer
stand, and a computer and peripheral equipment. Petitioner
testified that he used the business equipment in his home office.
For 1991 and 1992, petitioner also deducted utilities of $912 and
$957, respectively, representing one-third of the utilities
incurred on his personal residence, which he allocated to his
home office. Respondent denied these expenses on the ground that
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