- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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