Roger L. and Geraldine Williams - Page 14

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          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 Port             




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