- 12 - they have not substantiated the business nature of the expense. See sec. 274(d)(1). Petitioners claim legal and professional fees in the amount of $800. Of this amount, $300 was paid as a retainer to a lawyer for advice regarding petitioner’s citizenship. Petitioners have not established that this expenditure is related to their business. In the case of the other expenditure in the amount of $500, petitioners did not submit an invoice from the attorney or any other information regarding this expenditure, and petitioner’s testimony that he sought advice concerning a possible suit against the city of Philadelphia is too vague to substantiate the nature of the expenditure. We are not satisfied that petitioners have proven that either expenditure is a deductible business expense. Petitioners claim a deduction for repairs and main- tenance in the amount of $11,800. On brief, respondent concedes that petitioners made capital expenditures in the aggregate amount of $14,050 during 1993. Respondent concedes that petitioner paid $4,100 for construction work at the newsstand at Broad and Oxford Streets. Respondent also concedes that he paid $1,750 for the installation of steel plates and bars in the newsstand at Broad and Oxford Streets. Finally, respondent concedes that petitioner paidPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011