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expenses for the production of income to permit the deduction of
legal expenses for his suit for divorce. See United States v.
Gilmore, 372 U.S. 39 (1963)(finding that expenditures
attributable to litigating a divorce are personal regardless of
the potential consequences upon the taxpayer's fortunes because
the nature of the expense is determined by the origin and
character of the claim). Nor do we accept his explanation for
the deduction of his taxes in the wrong year as being with
reasonable cause and in good faith. We find that his
explanations do not demonstrate an honest misunderstanding of
fact or law that is reasonable in light of his experience,
knowledge, and education.
We have considered the other arguments of the parties, and
they are either without merit or not necessary in view of our
resolution of the issues in this case.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011