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substantiation. These expenses were incurred in connection with
the business of FDLS. Because respondent apparently has not
challenged Mr. Brayshaw’s claim that they were incurred in
connection with his role as an independent contractor--rather
than an employee--of FDLS, we hold that petitioners may deduct
the following substantiated travel-related business expenses on
Mr. Brayshaw’s Schedule C:
United Airlines flight -- March 13 $101.00
Cab fare -- March 13 21.00
Airport restaurant -- March 13 6.98*
Southwest Airlines flight -- March 20 161.00
National car rental -- March 20 41.12
Gas for rental car -- March 20 5.55
Meal - March 20 5.66*
National car rental -- March 26 39.59
United Airlines flight -- May 20 221.00
Meal -- May 20 7.20*
United Airlines flight -- June 10 126.00
National car rental -- June 10 29.22
United Airlines flight -- September 27 131.00
Magic car rental -- December 4 53.03
National car rental -- December 16 40.91
Gas for rental car -- December 16 3.09
993.85
*Petitioners are entitled to deduct these amounts, after application
of the 50 percent limitation of section 274(n).
See sec. 162(a). Petitioners are also entitled to deduct as a
Schedule C business expense the $90 petitioners paid for Mr.
Brayshaw’s American Physical Society dues. See id. However, Mr.
Brayshaw’s California State Bar dues are not deductible. As
discussed supra, because we cannot trace the source or treatment
of these funds, we find that this was not an expense paid by
petitioners which is deductible by them. See Deputy v. du Pont,
308 U.S. 488, 494 (1940); Hewett v. Commissioner, 47 T.C. 483
(1967).
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