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associations of approximately $1,185. On their 1999 return,
petitioners deducted $700 for “Taxes and licenses” on the
Schedule C for Dr. Rinker’s medical practice. Respondent allowed
this amount in full. It appears likely that petitioners included
the cost of Dr. Rinker’s medical license fee in the deduction for
“Taxes and licenses.” Petitioners have therefore not established
that they paid any amount relating to Dr. Rinker’s medical
license in excess of the amount respondent allowed. See Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933).
Dues to professional organizations are generally deductible
under section 162. Sec. 1.162-6, Income Tax Regs. Pursuant to
Cohan v. Commissioner, supra at 544, we allow a deduction of $550
for the remaining expenditures for Dr. Rinker’s professional
dues.
12. Internet Services
Dr. Rinker testified that she paid approximately $24 per
month for Internet access in 1999. She testified that she
maintained the account so that she could communicate with
patients via e-mail, but that she also used the account for
personal purposes. Dr. Rinker also testified that she paid
another charge in connection with her business use of the
Internet, but she could not recall whether she incurred the
charge in 1999 or 2000.
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