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expenses was that his condominium wasn’t “up to snuff” to the
point that he was comfortable meeting there with new clients or
other clients he wanted to impress.
Ms. Toya Turney (Ms. Turney) of the Nashville Electric
Service (NES), who was called by respondent, testified, based on
the records of NES, that Ms. Push had electrical power activated
in her name at 403 South Timber Drive on November 23, 1992. The
records of NES further reflected that, up until the trial date of
this case on October 26, 1999, Ms. Push’s utility account at 403
South Timber Drive remained active. Finally, Ms. Turney
testified that the NES electricity usage records for 403 South
Timber Drive indicated that someone was living at that location
during each of the years at issue. This testimony contradicts
petitioner's testimony that he used this property only 30 to 40
days per year.
On this record, the Court finds that the amounts expended by
petitioner, during 1994, 1995, and 1996, for the rental of a
condominium at 403 South Timber Drive in Nashville were not
ordinary and necessary expenses incurred in the conduct of
petitioner's trade or business. Thus, the Court holds these
expenses are not deductible by petitioners.
For 1994, petitioners deducted other expenses of $751.35 for
equipment, $147.39 for miscellaneous, and $770 for dues and
subscriptions. The equipment expenses consisted of several
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