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of care for their child during working hours. See, e.g.,
O’Reilly v. Commissioner, T.C. Memo. 1974-261 (and cases cited
therein). Congress has enacted a separate credit for child care
expenses, which is currently embodied in section 21. Indeed,
petitioners took advantage of that provision to claim a $30
credit on their 1999 tax return in addition to their Schedule C
deductions. However, the rule set forth in O’Reilly still
stands, and petitioners may not deduct the costs of child care as
section 162 expenses.
10. Bank Charges
Dr. Rinker testified that she incurred charges for the
processing of patients’ credit card payments and for maintaining
her business checking accounts. Petitioners provided no evidence
of the amounts of those bank charges. At trial, Dr. Rinker was
unable even to estimate the bank charges she incurred in 1999.
We therefore lack a sufficient basis upon which to estimate an
appropriate deduction. See Cohan v. Commissioner, 39 F.2d at
544.
11. Dues
Dr. Rinker testified that she paid dues and licensing fees
to several organizations related to her medical practice in 1999.
Dr. Rinker was unable to recall the precise amounts, but she
estimated that her State medical license fee for 1999 was $500
and that she paid dues to several medical colleges and
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