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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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