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Petitioner testified, at trial, that the primary reason for
his trips to Chapman Law School Library was to conduct legal
research for his business clients. Further, petitioner testified
that he found the Chapman Law School Library was superior to the
libraries that were closer to his residence.
Upon the basis of the record in this case, we find that the
primary purpose for petitioner’s trips to Chapman Law School
Library was to conduct legal research for his business clients,
and, therefore, said travel is directly connected to petitioner’s
business. Petitioner’s visits to his family, if such visits
occurred, were a secondary consideration. We hold for petitioner
on this issue, as modified by petitioner’s concession at trial.
2. Legal Fees
At issue in the present case are legal fees of $6,000 for
taxable year 2000 incurred by petitioner in connection with a
lawsuit and its subsequent settlement.
Petitioner maintains that the legal fees are deductible by
him under section 162 as ordinary and necessary business expenses
relating to his sole proprietorship. Respondent, however, argues
that the legal fees are nondeductible because the origin of the
claim in the underlying action is personal and not proximately
related to petitioner’s business.
In order to be deductible on Schedule C, an expense must be
directly connected with, or proximately result from, a trade or
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