Ragnhild A. Westby - Page 39

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                         d.  Legal and Professional                                   
               For the years at issue, petitioner claimed deductions for              
          legal and professional fees paid in connection with her law                 
          practice as follows:                                                        
                         Year                     Amount                              
                         1987                     $5,104                              
                         1988                     7,239                               
                         1989                     6,128                               
                         1990                     13,536                              
               Mr. Aunan’s workpapers reveal that the following entries               
          comprised the deducted amounts:                                             
               (a) For 1987, amounts of $158, $1,620, $760, and $2,566, for           
          a total amount deducted of $5,104;                                          
               (b) for 1988, amounts of $4,962 and $2,277, for a total                
          amount deducted of $7,239;                                                  
               (c) for 1989, amounts of $4,965, $88 and $1,075, for a total           
          amount deducted of $6,128;                                                  
               (d) for 1990, amounts of $18,066 and $10,470, reduced by a             
          $15,000 payment to James Van Valkenburg, for a total amount                 
          deducted of $13,536.                                                        
               Our review of the record reveals the following:                        
               (a) During 1987, petitioner paid fees to other attorneys of            
          $2,566, fees to law clerks of $760.02, fees to experts of                   
          $1,620.20, and fees for medical records of $158, for a total                
          expenditure of $5,104.22 (Ex. 38-R, lines 250-261, 317-319, 766-            
          777, 750-754).                                                              





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