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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.
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