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expense was not personal, the taxpayer must show that the expense
was incurred primarily to benefit his business and that there was
a proximate relationship between the claimed expense and the
business. Walliser v. Commissioner, 72 T.C. 433, 437 (1979).
Dr. Rinker testified as to the business purpose of some of
the expenditures, and the notes on the checks set forth an
adequate basis for allowing some deduction for purchases of
office supplies. At least two of the checks written to Fry’s
Electronics for $625.38 and to Cost Plus for $702.27 represent a
purchase of assets the cost of which should be capitalized, not
deducted. See sec. 1.263(a)-2(a), Income Tax Regs. We therefore
allow petitioners deductions for the full amount of check No.
2093, as well as for portions of check Nos. 9061 and 9167, which
represent deductible business expenditures. These amount to
deductions of $387.99 in total.
9. Child Care Expenses
At trial and on the brief, petitioners asserted that they
paid $8,951 for day care expenses of Dr. Rinker’s two children.
Dr. Rinker testified that she would not have been able to conduct
her medical practice without placing her children in day care.
Petitioners argued that the day care expenditures were deductible
business expenses.
We have consistently held that two-earner married couples
may not deduct, as a business expense under section 162, the cost
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