Ragnhild A. Westby - Page 44

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                         Year                Amount                                   
                         1987                $4,637                                   
                         1988                10,618                                   
                         1989                9,617                                    
                         1990                10,079                                   
               Mr. Aunan’s workpapers reveal that the following entries               
          comprised the deducted amounts:                                             
               (a) For 1987, amounts of $3,849 and $788, for a total amount           
          deducted of $4,637;                                                         
               (b) for 1988, a cumulative amount of $10,618;                          
               (c) for 1989, amounts of $9,490 and $127, for a total amount           
          deducted of $9,617;                                                         
               (d) for 1990, a cumulative amount of $10,079.                          
               Our review of the record reveals the following:                        
               (a) During 1987, petitioner paid, and respondent concedes              
          the deductibility of, contract services of $3,849.52 (Ex. 38-R,             
          lines 39-60) and $788.25 (Ex. 38-R, lines 790-799), for a total             
          amount documented of $4,637.77.                                             
               (b) During 1988, petitioner paid, and respondent concedes              
          the deductibility of, contract services of $10,759.31 (Ex. 39-R,            
          lines 696-755).                                                             
               (c) During 1989, petitioner paid, and respondent concedes              
          the deductibility of, contract services of $9,748.39 (Ex. 40-R,             
          lines 575-658 (excluding items conceded by petitioner)).                    








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