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apartment and 100 percent of his automobile expenses as allegedly
for business use. He deducted payments for clothing, bedding,
and cosmetics purchased at department stores and tickets to
entertainment events, claiming that they were gifts to
unidentified staff members. He deducted payments for laundry,
sunglasses, a bicycle, “erotic” Playboy tapes, children’s videos,
and tax protest materials.
No deduction is allowed for personal, living, or family
expenses. Sec. 262. Many of the items in dispute are inherently
personal, and we cannot conclude that they should be deductible
on the basis of testimony that is neither corroborated nor
credible.
Vague and Unpersuasive Testimony
The testimony that petitioner and his witnesses offered in
support of the disputed deductions was fatally vague and
unpersuasive. Petitioner deducted payments made to Morse, a
“preparatory legal assistant for a pro se”, as accounting and
legal expenses. Morse testified that he did “research on case
law * * * to justify some of * * * [petitioner’s] positions in
collection of * * * [petitioner’s] judgments.” Petitioner did
not send a Form 1099 to Morse, and neither he nor Morse produced
any billings from Morse to petitioner. The amount that was
claimed as a deduction was totally disproportionate to anything
in the record relating to attempts to collect from patients.
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