-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 thePage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: November 10, 2007