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represented by three checks payable to one of the other law firms
that represented petitioner. Therefore, of the $11,981.54 claimed
by petitioner as miscellaneous legal expenses on his return,
petitioner is entitled to a deduction of the $5,000 conceded by
respondent and $5,501.86 based on the evidence presented at
trial. This leaves a balance of $1,479.68, which the Court finds
has not been substantiated and, therefore, holds is not allowable
as a deduction.
As stated earlier, the income tax return submitted by
petitioner at trial included two Schedules C with respect to
trade or business activities engaged in by petitioner. One of
these activities was described as “Media Content and
Entertainment and Songs” with a business name of “Kirshner
Content and related entities”.4 The Schedule C reported gross
income of zero and various expenses. The activity was described
at trial as an activity of petitioner and another individual,
Robert Thurmond (Thurmond), as partners. Petitioner and Thurmond
referred to their affiliated activity as the Equisource Group.5
4 Petitioner’s other Schedule C involves an activity called
“Frexie”. Respondent made adjustments to that activity, and
those adjustments are addressed later in this opinion.
5 Since Kirshner Content was represented to be an activity
of petitioner and Thurmond, the Court assumes that the numbers on
the Schedule C represent petitioner’s allocable portion of the
expenses.
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