-7- that the payment might have otherwise given rise to a deduction for 1997 under section 162, but claims that $98,471 of that payment duplicates expenses already deducted by petitioner in prior years. As respondent views the matter, petitioners are not entitled twice to deduct the same expense. Petitioners agree with that principle, but argue that the rent deductions claimed in 1993, 1994, and 1995 do not relate entirely to the lease. According to petitioners, the rent expense deductions claimed in 1993, 1994, and 1995 include, in part, rent expenses connected to the lease, and, in part, rent expenses not connected to the lease. For example, petitioners claim that they paid $500 per month in storage fees for client records not stored on the premises covered by the lease. They also suggest that a portion of the rental expense deduction shown in 1993, 1994, and 1995 might have included some office in the home expenses. We reject petitioners’ claim on this latter point. There is insufficient evidence in the record to support any finding regarding the use of petitioners’ residence for business purposes during any of the relevant periods. We accept their claim, however, that a portion of the rent deduction claimed in the years 1993, 1994, and 1995 related to rent expenses not connected with the lease.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007