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On audit, petitioners substantiated $8,527 and $4,305 of
legal and professional expenses for 1990 and 1991, respectively.
In the notice of deficiency, respondent allowed petitioners to
deduct $4,647 and $3,000 of the substantiated expenses for 1990
and 1991, respectively, on the Schedules C. Respondent also
allowed petitioners to deduct $3,880 and $1,305 of the
substantiated expenses for 1990 and 1991, respectively, on their
Schedules A, subject to the statutory limitations, as tax
preparation fees. Respondent disallowed $96 of the amount
claimed for 1990 as unsubstantiated expenses.
Travel Expenses
On the Schedules C for 1989, 1990, 1991, 1992, and 1993,
petitioner claimed travel expenses of $4,830, $4,326, $2,721,
$3,532, and $3,686, respectively. On audit, respondent
determined that petitioners had substantiated travel expenses of
$2,525, $4,312, $2,742, $3,479, and $2,870 for 1989, 1990, 1991,
1992, and 1993, respectively. Respondent determined further that
some of the substantiated travel expenses did not relate to
petitioner’s law practice.
From January 26 through February 4, 1989, petitioner took a
trip to Minnesota. The airfare for that trip was $298. On
audit, respondent determined that the trip was not related to
petitioner’s law practice but, instead, was related to his
investments.
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