-38- line that called for lease expense. The amount was $7,476. In reviewing workpapers, that amount should have been classified as legal expense. It related to the legal cost that Cathy Michelsen had incurred related to a Tax Court proceeding dealing with taxable years 1993 through 1995 and paid to a law firm, the Joseph Mudd Law Firm. Those proceedings related to Tax Court Docket 14780-97. The reference to “TR 225:17-227:14” is to Michelsen’s direct testimony that she had a case in this Court in the “1999 time frame” and had received a bill from an attorney named Joseph Mudd for $7,632.75 of legal fees. We are unpersuaded that petitioners are entitled to deduct for 1999 the $7,476 claimed for that year as a lease (or, as they claim now, a legal) expense. b. Travel Petitioners argue that they have substantiated the $4,129 of expenses claimed as a business travel deduction through the introduction of Exhibit 123-P and the testimony of Michelsen. That evidence, petitioners conclude, proves that they traveled to Australia to attend the Sydney gift show, to search for a location in Australia to open a fourth Nature’s Touch store, and to identify merchandise to import into the United States. We disagree that petitioners are entitled to any of their reported travel expenses for 1999. Petitioners have simply not persuaded us that their trip to Australia was related primarily to Michelsen’s reported work for her sole proprietorship during 1999 as a “Corporate Director/Consultant”. Nor have petitionersPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: November 10, 2007