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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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