Gerald L. and Joy M. Zeidler - Page 23

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          question.  At trial, counsel for respondent advised the Court               
          that petitioners had established their entitlement to deductions            
          for all the disallowed expenses, except for the following                   
          expenses for the 1990 tax year:9                                            

          $930 -- Supplies                                                            
          162 -- Meals                                                                
          299 -- Other expenses                                                       
          909 -- Travel                                                               

               The Court sustains respondent on each of these items.                  
          Petitioners did not sustain their burden of establishing their              
          entitlement to a deduction for these expenses.  The meals and               
          travel expenses were additionally subject to the substantiation             
          requirements of section 274(d), discussed earlier in this                   
          opinion, and petitioners' records as to the meals did not comport           
          with the record keeping requirements of section 274(d).  The $909           
          travel expense item, however, was disallowed by respondent for a            
          different reason:  the expense related to that portion of Mrs.              
          Zeidler's travel with Mr. Zeidler on two trips during 1990.  One            
          trip was to North Carolina, and the other trip was to Birmingham,           
          Alabama.  Respondent allowed a deduction for that portion of the            
          trips allocable to Mr. Zeidler but denied the portion allocable             
          to Mrs. Zeidler on the ground that the trips, as to her, were not           

               Depreciation of the computer for the 3 years was also one of           
          the Schedule C expenses disallowed that respondent did not                  
          concede but that issue has been considered by the Court above.              

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