Larry Charles Miller - Page 7




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            find that petitioner has not proven that he is entitled to the                             
            $72,516 and $15,956.97 in office expense deductions.                                       
                        b.  Other Office Expenses                                                      
                  Other office expenses consist of deductions taken for:  (I)                          
            storage facility expenses; (II) the purchase of oriental rugs and                          
            art; and (III) language lessons.                                                           
                        (I).  Storage Facilities                                                       
                  Petitioner claimed storage facility expenses of $478 in 1993                         
            and $409 in 1994.  Petitioner testified that in 1993 he closed an                          
            office at Ventnor, New Jersey, and then stored the office                                  
            furniture at Access Storage.10  To substantiate his deductions,                            
            petitioner provided copies of checks totaling $478.5011 in 1993                            
            and $409.5012 in 1994.  The checks were drawn on the checking                              
            account that petitioner maintains for his law practice:  "Larry                            
            Charles Miller, Attorney at Law".  However, petitioner also                                
            testified that in the middle of 1994 he moved to a new house and                           
            that he also paid household expenses and personal expenses such                            
            as credit card debts and automobile expenses from the same                                 

                  10The deductions in 1993 and 1994 allegedly relate to the                            
            same office closing.                                                                       
                  11This amount consists of one check payable to Access Black                          
            Horse for $132, and two additional checks payable to Black Horse                           
            Self Storage for $165 and $181.50.                                                         
                  12This amount consists of checks payable to Black Horse                              
            Storage and Black Horse Pike Storage for $181.50 and $228,                                 
            respectively.                                                                              






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