James E. and Kathy Walker - Page 3

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               Petitioner, however, was not reimbursed by his law firm or             
          its corporate clients for his personal political contributions.             
          The corporations that petitioner's law firm represented were                
          prohibited by Oklahoma and Federal campaign finance laws from               
          making direct or indirect contributions for the election or                 
          reelection of candidates for public office.                                 
               Petitioner, individually, made political contributions in              
          1990 and 1991 in the amounts of $9,250 and $6,582, respectively,            
          in support of political candidates running for election or                  
          reelection in the Oklahoma legislature or the United States                 
          Congress.  The individual contributions usually ranged in amounts           
          from $50 to $200.  On their 1990 Federal income tax return,                 
          petitioners claimed a deduction for these political contributions           
          as a Schedule C lobbying expense.  The 1991 contributions were              
          claimed as Schedule A unreimbursed employee business expense                
          deductions.  Respondent disallowed all of the claimed deductions.           
               Respondent's determinations are presumed to be correct and             
          petitioners bear the burden of proving otherwise.  Rule 142(a);             
          Welch v. Helvering, 290 U.S. 111, 115 (1933).                               
               Section 162(a) allows the deduction of all ordinary and                
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business.  Deductions are strictly a               
          matter of legislative grace, and petitioners bear the burden of             
          proving their entitlement to any deduction claimed.  Rule 142(a);           






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