Interex, Inc. - Page 4

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               The only evidence offered at trial by petitioner was the               
          canceled check and the testimony of Olbres.  Olbres testified               
          that she never had any discussions with Coupounas as to how he              
          would charge petitioner for accounting and legal services.  She             
          acknowledged that it was not petitioner’s standard business                 
          practice to retain service providers or suppliers without knowing           
          what they were going to charge.  She attempted to explain her               
          reliance on Coupounas by reference to his history of preparation            
          of tax returns for her parents and for her.  Coupounas declined             
          to cooperate with petitioner’s counsel, and there are no                    
          documents in the record reflecting services allegedly performed             
          by Coupounas for petitioner other than the tax return prepared by           
               We are not persuaded that economic performance with respect            
          to the professional fees claimed had occurred during the year in            
          issue.  Coupounas never submitted an invoice to petitioner,                 
          unlike other suppliers with whom petitioner did business.  Based            
          on the testimony and lack of contemporaneous documentation, we              
          conclude that the amount of the professional fees for services              
          allegedly rendered by Coupounas could not have been determined              
          with reasonable accuracy by the end of 1994.  Olbres also                   
          testified that, at the time she signed the return, she was not              
          aware that more than $65,000 in professional fees expense was               

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