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of a promoter or manager. Mr. Richards did not adequately
address this issue at trial, and there is no evidence in the
record to further explain these expenses. We do not find these
expenses to be ordinary and necessary with regard to Mr.
Richards’ writing activity.
Fax
Petitioners claimed a deduction of $115 for the transmission
of scripts and lyrics by fax via retail establishments that
offered fax services. In the record are receipts for fax
services in the amount of $7. Petitioners did not maintain any
records detailing what was faxed and to whom. Without adequate
substantiation, we cannot allow this deduction. Therefore,
petitioners are not entitled to a deduction of $115.
Shipping
Petitioners claimed a deduction of $1,189 for shipping
costs. Mr. Richards claimed that he sent scripts via Federal
Express, United Parcel Service, and the U.S. Postal Service. Mr.
Richards would also send his screenplays and lyrics to himself by
U.S. registered mail for copyright protection of his work. The
record contains receipts from the U.S. Postal Service totaling
$439 for shipping costs and registered mail. While there are no
notations on the receipts as to what was shipped, there are
notations on some of the canceled checks that indicate that the
expenses were for Mr. Richards’ writing activity. We believe
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