James G. LeBloch and Cathy Michelsen LeBloch - Page 38




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               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 petitioners                 






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