- 5 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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