William J. Fleischaker and Donni L. Fleischaker - Page 30

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          The procedures require the taxpayer to complete the forms and                
          attachments in a clear manner and in accordance with their                   
          instructions.  See Rev. Proc. 92-23, 1992-1 C.B. 738.  The                   
          instructions for the Schedules C require a taxpayer to complete              
          separate schedules for each business of the taxpayer.  See                   
          Instructions for Schedule C, Profit or Loss from Business, for               
          1991 and 1992.                                                               
               Petitioners filed two Schedules C for each of the years at              
          issue, one for petitioner's oil and gas production activity and              
          another for petitioner's medical services practice.  Petitioner              
          does not contend that either activity included petitioner's                  
          activity with regard to Adult Living Centers or the development              
          of facilities for the elderly.  Petitioners did not complete a               

                    *      *      *      *      *      *      *                        
               (b) Certain Trade or Business Expenses (which, for                      
               purposes of this revenue procedure, include the                         
               following six expenses as they relate to the rental of                  
                    *      *      *      *      *      *      *                        
                    (2)  Legal Expenses:  The amount claimed must be                   
               stated.  This revenue procedure does not apply,                         
               however, to amounts properly characterized as capital                   
               expenditures or personal expenses, including amounts                    
               that are required to be (or that are) amortized over a                  
               period of years.                                                        
                    (3)  Specific Bad Debt Charge-off:  The amount                     
               written off must be stated.                                             

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