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As we understand it, petitioner claims that the second
payment that he received from Dr. Strom in the amount of
$26,700 consisted of an annual fee of $6,500 and the
reimbursement of three payments that petitioner allegedly
made on behalf of Dr. Strom in the aggregate amount of
$21,679.75 (viz, $2,679.75, $12,000, and $7,000). One
problem we have with petitioners's testimony is that the
total of the fees and reimbursements is $28,179.75, or
$1,479.75 more than Dr. Strom's check of $26,700. Another
problem we have with petitioner's testimony is that he does
not explain why, in preparing the check for Dr. Strom's
signature, to reimburse himself for payments made on
Dr. Strom's behalf, petitioner included the $7,000 payment
to the Employment Development Department that would be due
on December 31, 1990, several days later. We do not
understand why petitioner did not simply prepare a check
for this upcoming payment directly from Dr. Strom to the
Employment Development Department.
Petitioner contends that the payments made on
Dr. Strom's behalf in 1990 are deductible because
petitioner received reimbursement for those payments from
Dr. Strom, and petitioner included the reimbursements in
computing gross income for that year. Petitioner states in
his posttrial brief that he included fees of $28,560, from
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