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1994. The amount for 1993 consists of a joint venture payment to
Northwest and cash payments to prostitutes at Nevada's legal
brothels. Petitioner produced a canceled check reflecting his
payment to Northwest and a contemporaneous journal supporting his
deductions for amounts paid to prostitutes to research his book.
The amount for 1994 consists of a variety of expenses, for which
petitioner has provided no documentary or testimonial evidence,
with the exception of his expenses to interview prostitutes on
out calls, which he substantiated by personal credit card
receipts.
We allow petitioner to deduct the joint venture payment of
$4,350 for 1993. However, no deduction is allowed for the
interview expenses. We find that the expenditures incurred by
petitioner to visit prostitutes are so personal in nature as to
preclude their deductibility. In evaluating whether certain
expenses are personal or qualify as business expenses under
section 162, the Court has found that some expenses are so
"inherently personal" that they almost invariably are held
to come within the ambit of section 262.17 Fred W. Amend Co. v.
Commissioner, supra. All the other items constituting "other
expenses" for 1993 and 1994 are disallowed for lack of sub-
stantiation.
17Sec. 262 provides that "no deduction shall be allowed for
personal, living, or family expenses."
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