-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.
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