Charles and Beatrice M. Reynolds - Page 19




                                       - 19 -                                         

              We hold that petitioners have substantiated medical expenses            
         in 1993, deductible on Schedule A, of $9,160 paid for their                  
         dependent, Mrs. Maxey, and $1,419.71 of their personal medical               
         expenses that were not covered by medical insurance.  In 1994,               
         petitioners had medical expenses of $1,252 for health insurance.             
         Petitioners’ medical expense deductions are allowable to the                 
         extent they exceed 7.5 percent of their adjusted gross income for            
         each year.  See sec. 213(a).                                                 
         Issue 4.  Legal Expenses                                                     
              Petitioner claimed on his Schedules C for 1993 and 1994                 
         expenses for legal and professional services of $2,380 and $8,290,           
         respectively.  All of the expenses for 1993 and $5,615 of the                
         expenses claimed for 1994 relate to legal counsel petitioner                 
         engaged to represent him while he was being investigated by                  
         Inspection.                                                                  
              A.   Origin and Character of the Claim                                  
              The investigation concerned allegations that petitioner was             
         engaged in the private practice of law during government working             
         hours.  According to petitioners, the claimed legal expenses are             
         correctly claimed on Schedule C because the expenses are directly            
         related to petitioner’s practice of law.  The expenses are                   
         directly related to the law practice, petitioners argue on brief,            
         because “Such conduct, if proved, could result in sanctions                  
         against the law license of Petitioner Charles Reynolds in                    





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