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Legal and Professional Expenses
Petitioner claimed deductions on his 1990 and 1991 Schedules
C for legal and professional expenses. To the extent
substantiated, respondent allowed petitioners to deduct some of
the expenses on the Schedules C and, except for $96 for 1990, the
remainder on petitioners’ Schedules A as tax preparation fees.
Petitioners contend that the legal and professional expenses
in dispute for 1990 and 1991 encompass accountant’s fees for the
preparation of their tax returns and legal fees paid to other
lawyers. Petitioners assert that those legal and accountant’s
fees related to petitioner’s law practice.
Respondent contends that petitioners have not established
that they are entitled to deductions for legal and professional
expenses relating to petitioner’s law practice in amounts greater
than those already allowed by respondent. We agree.
Petitioners offered no proof at trial showing that the items in
dispute related to petitioner’s law practice as required by
section 162. See supra note 9. Thus, petitioners have not
established that they are entitled to deductions for legal and
professional expenses on the Schedules C in amounts greater than
those already allowed by respondent. Petitioners also have not
shown that they are entitled to amounts for legal and
professional expenses on the Schedules A in amounts greater than
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