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testified that the expenses may have related to the collection of
fees from clients. Petitioner did not present any documents or
other evidence as to this deduction. Petitioner failed to
provide the Court with evidence sufficient to establish a
rational basis upon which an estimate can be made. We sustain
respondent’s determination.
7. Office Expense
Petitioner deducted $2,014 for office expenses. At trial,
petitioner produced numerous receipts for items such as frames,
video repair, bottled water, flowers, books purchased at
Waldenbooks, videos, candy, and numerous purchases from Kinko’s.
The record is silent as to whether these expenses are related to
petitioner’s trade or business, and we sustain respondent’s
determination as to these items.
Petitioner submitted a receipt of $177.83 for business cards
and $19.25 for an address stamp. We hold that petitioner is
entitled to deduct these amounts.
Petitioner produced receipts of $26.45 and $157.23 for the
purchase of Macintax software manufactured by Chipsoft.
Petitioner also purchased Turbotax software for $69.85. Computer
software (software) is generally not currently deductible. Rev.
Proc. 69-21, 1969-2 C.B. 303. Section 197 provides that software
purchased by a taxpayer is amortizable over 15 years. Sec.
197(d). However, software that is readily available for purchase
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