Michael J. Rovell - Page 8

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          law practice courting high-profile clients who need to be “wined            
          and dined” is insufficient evidence to substantiate the amount he           
          claims.  Accordingly, we sustain respondent’s disallowance of               
          petitioner’s other miscellaneous deductions.                                
               Finally, with regard to the disallowance of other expenses             
          for books, fees, seminars, and dues in the amount of $5,700,                
          petitioner has failed to offer any evidence with regard to these            
          expenses; therefore, we sustain respondent’s total disallowance.            
               Based on the foregoing,                                                

                                             Decision will be entered                 
                                        under Rule 155.                               

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Last modified: November 10, 2007