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presented to substantiate these claimed expenses is a statement
from the State Bar of California, showing examination fees paid.
Petitioner paid $650 and $300 in examination fees for the 1994
and 1995 tax years, respectively. It is evident from this
statement and petitioner's testimony that the claimed expenses
were incurred over the period 1992 through 1997. Even if we were
to find that petitioner substantiated these expenses, and the
expenses were incurred in 1994 and 1995, these expenses must be
disallowed. Petitioner's educational expenses are not deductible
under section 162 as an ordinary and necessary business expense
as these expenditures qualify him for the new trade or business
of the practice of law. See Wu v. Commissioner, T.C. Memo. 1991-
100; sec. 1.162-5(b)(3)(i) and (ii) (Ex.1); see also Taubman v.
Commissioner, 60 T.C. 814 (1973); Meeks v. Commissioner, T.C.
Memo. 1998-109; Meredith v. Commissioner, T.C. Memo. 1993-250;
Harper v. Commissioner, T.C. Memo. 1990-239.
Petitioner has not presented any substantiation, with the
exception of the above, for any of the expenses claimed.
Although petitioner provided the Court with numerous papers, none
contained receipts, bills, invoices, records, etc. Even the
documentation that was provided was not for the years 1994 or
1995. In a previous motion to continue this case before the
Court, petitioner testified that his car was broken into and the
pertinent documents were taken. At trial in the instant matter,
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