Richard Lewis Field - Page 10

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          has failed to meet his burden of proof, and the deductions are              
          accordingly disallowed.                                                     
               3.   Other Expenses Reported on Schedule C                             
               For 2000, petitioner claimed deductions for the following              
          expenses paid by Field Investment Management: (1) $2,056 for                
          commissions and fees; (2) $692 for office expenses; (3) $225 for            
          office supplies; (4) $103 for computer repair and maintenance;              
          and (5) $514 for a computer.                                                
               Petitioner provided copies of miscellaneous checks,                    
          receipts, and invoices to substantiate the office expenses, the             
          cost of the computer and its repair and maintenance, and supplies           
          for 2000.  Petitioner’s evidence sufficiently documents the                 
          amount of the expenses incurred.  However, he has not                       
          sufficiently shown that such expenses were incurred primarily to            
          benefit his investment activities rather than for personal                  
          reasons.  Therefore, the deductions are disallowed under section            
          262.                                                                        
               As for the commissions and fees, petitioner provided a stack           
          of statements from numerous credit card companies to substantiate           
          their deductibility.  He contends that the cash advance charges             
          and the annual fees charged by the banks were used to fund                  
          demonstration stock portfolios for Field Investment Management.             
          However, petitioner has not presented any evidence with respect             







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