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a total of $130. For 1992 respondent allowed petitioner 7-1/2
days at $26 per day for a total of $195. For 1993 respondent
allowed petitioner 14-1/2 days at $26 per day for a total of
$416.6 Respondent disallowed $1,592, $597, $324, $886, and $2,104
of the meal and entertainment expenses claimed on the Schedules C
for 1989, 1990, 1991, 1992, and 1993, respectively.
Bad Debt Deduction
During November 1991, Ted Kadrlik (Mr. Kadrlik) asked
petitioner to represent him on check fraud charges. Mr. Kadrlik
gambled, causing financial hardship for his family. Petitioner
declined to represent Mr. Kadrlik, but petitioner agreed to
advance Mr. and Mrs. Kadrlik (the Kadrliks) some money. On
November 25, 1991, petitioner gave the Kadrliks a check for $300.
The check memo line contained the notation “Loan”. The Kadrliks
did not give petitioner a promissory note relating to the $300
payment. The Kadrliks did not repay the money. Petitioner asked
the Kadrliks for the money a few times, but he made no other
attempt to collect on the debt. He believed that it would not be
appropriate to sue the Kadrliks for collection because of their
6The parties stipulated that respondent allowed petitioner
$416 for 1993 calculated on the basis of $26 per day for 14-1/2
days. Our calculation, however, shows that the meal allowance
would be $377 ($26 per day multiplied by 14-1/2 days). The
parties do not explain the discrepancy, nor does the record
clarify the difference in calculations. In the absence of an
explanation, however, we defer to, and accept, the parties’
stipulation. See Rule 91(e).
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