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failed to introduce any evidence to show that the recalculation
is required.
Petitioner has substantiated her depreciation and section
179 expense deduction for each of the years at issue, and the
deductions in the amounts claimed are allowed.
b. Bank Service Charges
Petitioner deducted bank service charges on her Schedules C
for the years at issue as follows:
Year Amount
1987 $469
1988 1,035
1989 120
1990 120
A review of petitioner’s bank records establishes that
petitioner incurred service charges, insufficient funds charges,
returned item charges, and miscellaneous other charges such as
those for check orders. For example, during 1987, with regard to
petitioner’s ANB account No. 302-733-1 alone, petitioner paid
$184.25 in service charges, $413 in insufficient fund and
returned item charges, and $84.75 in check charges for 10 months
(bank statements for 2 months were missing). Although all of
petitioner’s bank records were not introduced into evidence, we
have no doubt that in each of the years at issue petitioner paid
bank charges related to her law practice. Applying the Cohan
rule, we allow petitioner the deductions claimed for bank service
charges for each of the years at issue.
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