Eng Guek Kang - Page 17




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          Commissioner, T.C. Memo. 1999-250.  Mr. Ngo has not introduced              
          evidence supporting a deduction in excess of that determined by             
          respondent for 1995.  Accordingly, respondent is sustained on               
          this issue for 1995.                                                        
               In regards to 1997, Mr. Ngo’s business ledger reflects                 
          $11,448.63 in legal and professional fees incurred during 1997.             
          After review of the business ledger, we find that $6,269.43 was             
          not legal in nature, but instead pertained to various                       
          professional fees including window service and electrician fees.            
          Accordingly, these amounts are not allowed as legal and                     
          professional fees.6  Additionally, of the $5,179.20 balance, $300           
          was paid to K.B. for accounting fees and $4,879.20 was paid to              
          Clement Law Center.  Mr. Ngo did not testify as to the purpose of           
          services rendered by Clement Law Center.  We also find that Mr.             
          Ngo has failed to show that the claimed legal expenses of                   
          $4,879.20 were incurred in carrying on his or Donut Star’s trade            
          or business.  Accordingly, Mr. Ngo is entitled to $300 in legal             
          and professional fees for 1997.                                             
               4. Repair/Maintenance                                                  
               Mr. Ngo claimed repair/maintenance deductions of $315 and              
          $15,860 for 1995 and 1996, respectively.  Respondent disallowed             
          these claimed deductions.                                                   
               Mr. Ngo’s business ledger shows a total of $6,684.36 for               


               6    See infra Repairs and Maintenance.                                





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