Richard and Judith Haeder - Page 17




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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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