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petitioners are entitled to a deduction for business insurance
for $1,775.88, representing 12 monthly payments of $147.99.
d. Legal. Petitioner stated the names of several attorneys
with whom JDB had some relationships, but he was not able to
describe those relationships or indicate the amounts of the
respective legal fees paid. The Court kept the record open for
60 days in order for petitioner to contact those attorneys to
obtain substantiating documentation. Nothing has been received
from petitioners. Accordingly, we are unable to speculate on the
amount of legal fees petitioners expended as ordinary and
necessary business expenses, or to allow a deduction for any such
fees. Vanicek v. Commissioner, supra.
e. Home office. The claimed deductions for office expense,
rent expense, and utilities all pertain to this subject. Suffice
it to say that petitioners have failed to show that they used and
maintained regularly and exclusively any part of their home for
business purposes or any verification of the claimed
expenditures. We sustain respondent’s disallowance of these
items.
f. Repairs. We are not sure what this claimed expenditure
consists of, although vehicle repairs probably make up the
largest part thereof, if not all. Any vehicular repair expenses
would be covered by the rules of section 274(d). As to any other
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