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In support of the deductibility of this amount, petitioners
produced canceled checks showing the following payments:
Date Payee Amount
01/25/96 Ron Lawson $ 250.00
02/14/96 Seymour Rosenberg 100.00
04/13/96 AAA Auto Club South 59.00
11/09/96 Sam's Club 59.54
Total $ 468.54
The check to Ron Lawson was signed by petitioner; however, the
others were signed by petitioner wife and were written on
petitioners’ joint account. The check to Ron Lawson listed no
notation in the memo section. The checks to Sam's Club and AAA
Auto Club South, respectively, listed 9-digit and 11-digit
numbers in the memo section which appear to be account numbers.
The check to Seymour Rosenberg has a notation of “Business
Advice” in the memo section. No evidence was presented to show
the relationship of Ron Lawson or Seymour Rosenberg to
petitioner’s business activities. Moreover, no evidence was
presented that would indicate any of these payments was incurred
in petitioner’s trade or business. The Court holds that these
expenses are not deductible.
The remaining rent or lease expenses at issue, i.e., $5,500
for 1994, $5,832.62 for 1995, and $6,595 for 1996, constitute
amounts paid by petitioner for rental property in Nashville,
Tennessee. Throughout the years at issue, petitioner rented a
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