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where there is a mixture of business and personal aspects, some
discretion is permitted to determine which considerations
predominate and whether any part of the expenditure may qualify
for a deduction. See Feldman v. Commissioner, supra at 464;
Heineman v. Commissioner, 82 T.C. 538, 542 (1984) (the
distinction between business expenses and personal expenses is
based on a weighing and balancing of the facts and circumstances
in each case); Sharon v. Commissioner, supra at 524 (a weighing
and balancing of the facts is required to give the business and
personal characteristics their proper order of importance).
We agree with respondent that the hours Mr. Speltz spent
picking up mail and groceries and those spent transporting
firewood without children are not sufficiently business oriented
to warrant an expense deduction. Nonetheless, Mr. Speltz
completed a substantial number of hours of business-oriented
services for the daycare that Mrs. Speltz credibly substantiated.
We therefore find that the medical expense deductions
attributable to Mr. Speltz’s business-oriented activities were
ordinary and necessary business expenses of the daycare.
Whether the Payments Were Reasonable in Amount
We must also determine whether the amounts paid to Mr.
Speltz as compensation were reasonable in amount. Mr. Speltz was
paid $3,279 in 2000 and $4,539 in 2001. Whether amounts paid as
wages are reasonable compensation for services rendered is a
question of fact to be decided on the basis of the facts and
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