- 32 - surveillance business, represented computer fees paid to on-line service providers for individual background check information, including addresses, Social Security numbers, credit information, and so on. The checks submitted by petitioner at trial substantiate that such expenses were incurred, and they are consistent with his trial testimony. Based on the record, we find that these amounts were ordinary and necessary expenses incurred by petitioner in carrying on his business under section 162. I. Postage For 1991 and 1992, petitioner deducted postage in the amounts of $394 and $402, respectively. Respondent completely disallowed these expenses. In many instances, petitioner failed to show the business purpose for the postage expense claimed. For example, in 1991 petitioner purchased 600 stamps at 29 cents apiece; however, the record is silent as to the use of the stamps in petitioner's business. In 1992, petitioner conceded that he posted the newsletter for the Rotary group. However, petitioner has not established that this newsletter postage is a business expense. These examples are indicative of the entire record regarding this matter. Nevertheless, it is still reasonable to infer that petitioner incurred postage costs for TSI. At trial, petitioner submitted bills which we know he mailed out to clients.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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