Gerry M. Griggs - Page 6

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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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