- 15 - $16,972 and $16,945, in 1996 and 1997, respectively. Respondent allowed $15,520 and $11,067, respectively. At trial, Mr. Ngo provided rent statements for 1996 and 1997 from PHI Excess Properties showing the amounts paid by Mr. Ngo on behalf of Donut Star. We find that Mr. Ngo has satisfied his burden to substantiate the rent or lease payments made on behalf of Donut Star during 1996 and 1997. Mr. Ngo’s claimed deduction is sustained. 2. Utilities Mr. Ngo claimed utility expense deductions of $8,180 and $7,922 in 1995 and 1997, respectively. Respondent allowed $5,929 and $2,033, respectively. After reviewing the record, we find that Mr. Ngo’s business ledger sufficiently supports, and thus substantiates, the utility expenses of Donut Star in the following amounts. For 1995, Mr. Ngo is entitled to a total deduction of $7,897.54. For 1997, Mr. Ngo is entitled to a total deduction of $4,355.82. 3. Legal and Professional Fees Mr. Ngo claimed a deduction for legal and professional fees of $600 and $4,861 in 1995 and 1997, respectively. Respondent disallowed $300 in 1995 and the entire amount in 1997. Generally, legal fees may be deductible under section 162(a) only if they are connected to a taxpayer’s trade or business. See Guill v. Commissioner, 112 T.C. 325, 328-329 (1999); Davis v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011