Steven and Jennie Jacobs - Page 11

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            we find that petitioner made trips to Virginia City on an average                             
            of three times per week during 20 weeks during the year, for a                                
            total of 4,800 miles.  At the standard business mileage rate of                               
            28 cents per mile in effect for 1992 under Rev. Proc. 91-67,                                  
            supra, petitioner is entitled to a mileage allowance deduction                                
            for local travel of $22.40 per day, or a total of $1,344.  We                                 
            sustain the balance of respondent's disallowance of petitioner's                              
            claimed car and truck expense deduction.                                                      
            4.    Legal and Professional Expenses of $3,342                                               
                  Petitioner testified that "primarily" the $3,342 was paid                               
            for production costs and that a "small amount" was for legal                                  
            expenses.  Petitioner testified that the production costs                                     
            included both amounts paid to the production assistant in                                     
            Virginia City and amounts paid to sound engineers.  Petitioner                                
            testified that he worked with the production assistant to                                     
            determine a budget and how much of the fee petitioner would keep                              
            and how much the production assistant would keep.  However,                                   
            petitioner presented no invoices or other documentation showing                               
            how the services of the production assistant were billed and paid                             
            for.  Although petitioner testified that he reported the gross                                
            amounts paid under the contracts, it is not clear--indeed it                                  
            seems unlikely--that the production assistant's share was part of                             
            the gross income reported by petitioner.  We do not believe that                              







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