Douglas L. and Nancy H. Maxfield - Page 5

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               CSCI is, using petitioner’s words, “an umbrella business               
          that deals in legal issues, construction issues, any [sic]                  
          advice.”  While petitioner allegedly gives legal advice, he does            
          not practice law.  Apparently, the construction aspect of CSCI              
          during the years before the Court involved property belonging to            
          the parents of petitioner Nancy H. Maxfield.  Petitioner also was           
          a “hearing officer for section 8 assistance and terminations” in            
          Prince George’s County, Maryland, for which he was paid                     
          $4,987.50.                                                                  
               Petitioner’s records for the deductions listed above                   
          consisted of credit card monthly statements.  With respect to the           
          expenses for car, repairs, and a portion of the insurance the               
          deductions allegedly relate to petitioner’s expenses for local              
          transportation.  Petitioner claimed deductions for both alleged             
          mileage and actual expenses.  The travel and lodging expenses               
          relate to trips to California, Florida, and Texas by automobile,            
          and to Alaska and Washington State by airplane.  Petitioner did             
          not maintain any logs or similar type records concerning the                
          automobile or travel expenses.  The deductions for insurance                
          include insurance for automobiles, a boat, homeowners insurance,            
          and life insurance on petitioner.                                           
               At trial respondent was willing to allow the following cost            
          of goods sold and deductions for trade or business expenses:                







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