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entitled under section 162 to deductions for these payments as
ordinary and necessary expenses incurred in carrying on Dr.
Rinker’s medical practice. See Hagman v. Commissioner, T.C.
Memo. 1999-42. Nor does the record establish that Dr. Rinker
abandoned her pursuit of the proposed venture during 1999. Her
payments to financial and legal advisers are therefore not
deductible in that year pursuant to section 165. See sec.
165(c)(2); Hagman v. Commissioner, supra.
b. Payments to Secretaries and Bookkeepers
Dr. Rinker testified that she engaged several people for
temporary secretarial work, bookkeeping, and accounting in 1999.
At trial, Dr. Rinker was unable to recall how much she paid her
secretaries, except that in most cases she believed she paid each
of them less than $600. Dr. Rinker did recall, however, that she
hired bookkeepers for $25 an hour, and that they usually worked 6
or 7 hours per week. On cross-examination, Dr. Rinker admitted
that she engaged the same people to perform bookkeeping and tax
accounting services for both her business and personal needs.
Petitioners presented canceled checks written by Dr. Rinker
in 1999 made out to the people about whom she testified. In the
memo section of most of those checks, Dr. Rinker had written
notes identifying the services underlying the payments, such as
“12.5 hours bookkeeping” or “temp. office” or “sec. services.”
However, Dr. Rinker admitted that one of the checks in the
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