David J. Boyd - Page 4

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          Petitioner did not keep a log in the use of his vehicles, nor did           
          he produce any other contemporaneous record of his car and truck            
          expenses, the business use of his vehicles, or parking expenses.            
               Petitioner also claimed expenses in taking clients out for             
          meals.  He did not keep contemporaneously prepared records in               
          connection with these expenses.  At trial, he claimed $2,694.76             
          for meals expenses, which he determined using his annual                    
          statement from American Express.  As previously noted, the credit           
          card statement was not produced at trial.                                   
               Petitioner’s claimed expenses also included expenses related           
          to playing golf with clients.  He maintained a membership at the            
          Cincinnati Athletic Club, for which he paid dues.  Petitioner did           
          not keep a record of these client entertainment expenses.                   
               Petitioner had a professional relationship with a local                
          union, the United Food and Commercial Workers Union (UFCW), Local           
          1099.  Incident to this relationship, petitioner was allowed                
          membership in the union in order to obtain favorable health                 
          insurance coverage for himself and his wife.  The union dues were           
          $25 per month, which amounted to $300 a year.  Petitioner                   
          substantiated only $275 of union dues paid to UFCW Local 1099               
          during 1995.                                                                
               Petitioner claimed, as business expenses, charitable                   
          contributions to various organizations that solicited him at his            
          law office.  He stated that he made the contributions “in my                





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