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expenses nor has petitioner substantiated such expenses by other
sufficient evidence. Johnson v. Commissioner, supra. We reject
petitioners’ position because we find that petitioners did not
substantiate the actual expenses.
We agree that petitioners are entitled to claim the
incidental expenses, as computed in accord with Johnson, and as
allowed by respondent in the notice of deficiency.
Accordingly, we sustain respondent’s determination.
Contentions we have not addressed are irrelevant, moot, or
meritless.
Decision will be entered
for respondent.
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Last modified: May 25, 2011