- 33 -
Accordingly, we allow petitioner to deduct $50 annually for
postage. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).
J. Dues and Subscriptions
For 1991 and 1992, petitioner claimed dues and subscriptions
of $1,211 and $712, respectively. Respondent disallowed these
amounts, except for $100 incurred by petitioner in 1991 to renew
his private investigator's license, $125 paid both in 1991 and
1992 to the California Association of Licensed Investigators, and
two payments of $20 each made in 1992 to the Northern California
Fraud Investigators Association.
For 1991, petitioner deducted membership fees to the Rotary
Club, as well as to the Office Club, Costco, and Price Club,
which are all retail stores, and the Alameda Golf Club. For
1992, petitioner deducted membership fees to the Rotary Club, the
Alameda County Leaders Council, and the Retired Peace Officers
Association. Petitioner did not explain the facts and
circumstances of such expenses, nor is the business purpose of
these expenses self-explanatory from any business relationship of
petitioner with the expenses incurred. Lattin v. Commissioner,
T.C. Memo. 1995-233. Moreover, petitioner is unable to trace any
of his clients directly to these contacts.
Thus, we find that these items are nondeductible personal
expenses under section 262.
The balance of the 1991 and 1992 deductions are for various
newspapers, magazines, and legal books, such as Investigative
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