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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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