David J. Boyd - Page 3

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               Petitioner’s law practice involved litigation in which he              
          regularly made court appearances throughout the State of Ohio.              
          He had an American Express card that he used exclusively for                
          business purposes.  His law practice expenses, such as meals,               
          hotel, and entertainment expenses, were charged to the credit               
          card.  Petitioner was provided monthly statements and an annual             
          summary of expenses charged to the card.  Petitioner did not                
          offer into evidence any American Express statements or the 1995             
          annual summary.                                                             
               Petitioner and his wife owned two family vehicles.                     
          Petitioner used both of these vehicles in his law practice and              
          incurred vehicle expenses going to court and keeping client                 
          appointments in different parts of Ohio.  Other vehicle expenses            
          were incurred in commuting to his office and paying parking                 
          charges.  At trial, petitioner claimed a total of $5,873 in car             
          and truck expenses, which he derived by taking a “reasonable                
          proportionate share” of his lease payments, auto repairs, oil               
          changes, tuneups, tires, and other vehicle expenses from his                
          check records.  He also claimed $975 in parking expenses.                   


               2(...continued)                                                        
          professional corporation to perfect the Form 1120 for 1995.                 
          Respondent has not raised as an issue that the law practice                 
          activity conducted by petitioner was an activity of the                     
          professional corporation.  This case, therefore, is based upon              
          petitioner’s activity in the practice of law rather than that of            
          a professional corporation.                                                 





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