Ragnhild A. Westby - Page 67

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          satisfied from the documentation that was introduced that                   
          petitioner maintained the credit card accounts in question and              
          that she used them for her law practice.  We are also satisfied             
          that, at the time Mr. Aunan prepared petitioner’s returns for the           
          years at issue, he had documentation of the credit card interest            
          paid by petitioner during the years at issue.                               
               With respect to the capital loan interest deducted,                    
          petitioner produced copies of information returns that confirmed            
          the interest expense paid with respect to petitioner’s business             
          loans for 1988, 1989, and 1990.  The amounts documented                     
          corresponded exactly with the amounts shown on Mr. Aunan’s                  
          workpapers.  Although petitioner did not introduce into evidence            
          copies of her interest statements for 1987, we believe that there           
          is a sufficient factual predicate in the record to support a                
          finding that petitioner incurred interest expense attributable to           
          her business loans and credit card accounts as claimed on her               
          1987 Schedule C.                                                            
               Petitioner paid interest expenses as claimed on her                    
          Schedules C for the years at issue and reflected on the chart at            
          page 79 of this opinion.                                                    
                         q.  Travel                                                   
               For the years at issue, petitioner claimed deductions for              
          business travel as follows:                                                 








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