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In the notice of deficiency, respondent allowed petitioners
to deduct $65, $3,768, $957, $794, and $1,174 of the
substantiated expenses on the Schedules C for 1989, 1990, 1991,
1992, and 1993, respectively. Respondent also allowed
petitioners to deduct $714 and $201 of the substantiated expenses
for 1989 and 1993, respectively, as medical expenses on their
Schedules A, subject to the statutory limitations. In addition,
respondent allowed petitioners to deduct $298, $544, $1,168,
$1,624, and $1,122 of the substantiated expenses for 1989, 1990,
1991, 1992, and 1993, respectively, as investment expenses on
their Schedules A, subject to the statutory limitations.
Meal and Entertainment Expenses
On the Schedules C for 1989, 1990, 1991, 1992, and 1993,
petitioner claimed meal and entertainment expenses, before
statutory limitations, of $2,508, $1,760, $535, $1,302, and
$3,046, respectively. On audit, respondent determined that
petitioners had not submitted adequate substantiation for the
meal and entertainment expenses claimed. Nonetheless, respondent
allowed petitioner per diem amounts, for travel related to his
law practice, for those nights that petitioner verified he was
away from home. Thus, for 1989 respondent allowed petitioner 37
days at $14 per day for a total of $518. For 1990 respondent
allowed petitioner 39 days at $26 per day for a total of $1,014.
For 1991 respondent allowed petitioner 5 days at $26 per day for
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