-14- that although such records existed at one time, they were lost when he moved his office. Based on our opportunity to observe Mr. Hughes at trial, we are unable to accept his testimony uncritically. Nevertheless, and despite what appears to us to be a convenient lack of records, we are satisfied that petitioners incurred some deductible expense for Mr. Hughes' services in 1993. Thus, bearing heavily against petitioners, whose inexactitude is of their own making, we hold that petitioners are entitled to deduct $250 in "Legal Services" in 1993. Cohan v. Commissioner, supra at 543-544. Accordingly, respondent's determination on this issue is partially sustained. 4. Rent Petitioner claimed a deduction for "Rent, business" in the amount of $5,036. Petitioners contend that this amount represents the sum of (1) rent paid to SeaTac Airport under the Port lease, and (2) amounts paid to Red Lion for the use of its shoeshine stand. In the notice of deficiency, respondent allowed $1,330 of the claimed deduction and disallowed the balance for lack of substantiation. However, at trial, respondent conceded that petitioners are entitled to deduct an additional $1,298. The sum of these two amounts, $2,628, represents the following: (1) Rent for 6 months in the monthly amount of $300 paid to the Port (i.e., $1,800); (2) rent in the amount of $226 paid to the PortPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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