James G. LeBloch and Cathy Michelsen LeBloch - Page 37




                                        -37-                                          
               [sic] counsel may raise.  Petitioners believe they                     
               should prevail.                                                        
          We sustain respondent’s determination that petitioners are not              
          entitled to deduct these claimed expenses (except for $3,668 that           
          respondent concedes is deductible).                                         
               2.  1998                                                               
               Of the Schedule C expenses (other than home office                     
          deduction) disallowed for 1998, petitioners do not challenge any            
          of those expenses.                                                          
               3.  1999                                                               
               Of the Schedule C expenses (other than home office                     
          deduction) disallowed for 1999, petitioners challenge only the              
          expenses for lease ($7,476), travel ($4,129), and meals ($9,789).           
                    a.  Lease Expense                                                 
               Petitioners argue that the $7,476 claimed as a lease expense           
          was actually a legal expense that is deductible as such.  We do             
          not find that any of that amount is deductible.  Petitioners’               
          entire argument in brief as to this point is that “The amount               
          listed on Schedule C for lease expense was misclassified.  The              
          $7,476 amount related to legal fees related to a tax litigation             
          matter and should be fully deductible (TR2-130:1-12; TR 225:17-             
          227:14)”.  The reference to “TR2-130:1-12” is to the following              
          testimony by LeBloch on direct examination:                                 
                    There is a mistake on the Schedule C attached to                  
               the 1997 [sic] return, and the mistake is a                            
               misclassification.  There was listed an amount on the                  






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