Jane B. Oliver and Robert P. Oliver - Page 17

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          reimbursement, because of the broken pipes in their kitchen.  The           
          claim is separate and apart from the claimed casualty losses due            
          to flood damage that year.                                                  
              Petitioners calculated the $12,566.62 claimed loss to their            
          kitchen pipes by totaling the amount they claim to have spent               
          repairing the damage caused by the broken pipes.  They received             
          an invoice and a statement totaling $2,175.72 for repairs                   
          performed as a result of their broken kitchen pipes.                        
               Washington County, Mississippi, the county in which                    
          petitioners lived in 1991, was declared a Presidential disaster             
          area as a result of the floods in February and April of 1991.  At           
          trial, petitioners claimed that they are entitled to relief under           
          section 165(i) with respect to casualty losses suffered by them             
          during 1991.                                                                
          Claimed Deductions for Legal and Professional Expenses                      
               On Schedule C of their Federal income tax returns for 1990             
          and 1991, petitioners claimed deductions for business legal                 
          expenses of $10,000 in 1990 and $13,000 in 1991.  In respondent's           
          notice of deficiency the claimed business expense deductions for            
          legal fees were disallowed on the ground that petitioners had not           
          established that they constituted ordinary and necessary business           
          expenses.                                                                   
               Beginning in 1989, Mrs. Oliver was represented by John D.              
          Delgado, an attorney, in a criminal case which arose out of her             
          activity of keeping the books of Dr. Oliver, a physician.                   




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