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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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