George A. and Christine M. Evan - Page 19

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          do not conclude that petitioners established that these expenses            
          were for anything other than “personal, living, or family”                  
          purposes.  See sec. 262(a).  As concluded above, Mr. Evan was not           
          in a trade or business as a professor or real estate broker                 
          during the years in issue.  Mr. Evan was the primary caregiver              
          for his youngest children during the years in issue.  As a                  
          result, we conclude that the reported expenses for 1997 have not            
          been sufficiently substantiated and hold that petitioners are not           
          entitled to deductions for these expenses for 1997.                         
               As noted above, the parties provided no summaries as to the            
          expenses reported for 1998, and petitioners provided no further             
          substantiation of these expenses on the record.  Therefore, we              
          also hold that petitioners are not entitled to a deduction for              
          these expenses for 1998.                                                    
               In reaching our holdings herein, we have considered all                
          arguments made, and, to the extent not mentioned above, we                  
          conclude that they are moot, irrelevant, or without merit.                  
               To reflect the foregoing,                                              


                                                       Decision will be               
                                                  entered for respondent.             













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