Terry and Kathryn A. Roditski Dilozir - Page 5

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               Respondent argues that petitioner's claimed rent expense               
          represents a duplication of his claimed office expense,                     
          previously allowed by respondent.                                           
               The amount of office expenses claimed by petitioner and                
          allowed by respondent, $5,445.55, is greater than the "personal             
          expenses" in the amount of $4,382.48 indicated in the letter.               
          Moreover, respondent has allowed petitioner's claims for other              
          expenses in addition to office expenses.  Consequently, we                  
          conclude that petitioner's claimed rent expense represents a                
          duplication of expenses previously allowed by respondent.2                  
               Petitioners have failed to establish that they are entitled            
          to the claimed rental expense deduction in the amount of                    
          $3,271.90.  Rule 142(a).  We, therefore, sustain respondent's               
          determination on this issue.                                                
               (b)  Claimed Bad Debt Deduction                                        
               On June 2, 1992, petitioner and an associate, Peter                    
          Kostochko, agreed to purchase a dwelling located at 107 Mill                
          Street, Glastonbury, Connecticut, for $99,000.3  Petitioner paid            

               2  We are also troubled by a discrepancy between the figures           
          indicated in the letter and other items in the record.  The                 
          amount indicated as "fixed expenses" in the letter, $3,271.90, is           
          greater than 35 percent of $8,638, the amount of gross                      
          commissions indicated on the Form 1099.  Respondent objected to             
          the admissibility of the letter on the basis of hearsay.  While             
          we have admitted the letter, we have previously concluded that              
          the claimed expenses are a duplication of other expenses claimed            
          by petitioner and allowed by respondent.                                    
               3  The record does not indicate the precise nature of Mr.              
                                                             (continued...)           




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