Terry U. Neal - Page 14




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          required to accept self-serving testimony in the absence of                 
          corroborating evidence.  See Niedringhaus v. Commissioner, 99               
          T.C. 202, 212 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77              
          (1986).  Moreover, the Court is not convinced that petitioner               
          incurred any job hunting expenses in excess of those allowed by             
          respondent.  Consequently, on this record, the Court holds that             
          petitioner is not entitled to any miscellaneous itemized                    
          deductions, for 1994, in excess of those allowed by respondent.             
               The final issue is whether petitioner is entitled to trade             
          or business expenses for 1994 in excess of those allowed by                 
          respondent.  On Schedule C, Profit or Loss From Business, of his            
          1994 return, petitioner reported $5,377 for gross receipts and              
          claimed $8,799 for total expenses in connection with a computer             
          services activity.  The expenses consisted of $907 for car and              
          truck expenses, $14 for commissions and fees, $3,614 for                    
          depreciation, $11 for office expenses, $236 for rental of                   
          vehicles, machinery, and equipment, $375 for supplies, and $3,638           
          for other expenses.5  "Other expenses" included $1,440 for                  
          telephone expenses, $250 for storage, $58 for professional                  
          journals, $450 for contract labor, $316 for software, and $1,124            
          for diskettes.  Respondent disallowed $2,069 of these expenses,             


          5                                                                           
               These figures total $8,795 rather than $8,799; however, this           
          apparent mathematical error is not relevant to the Court's                  
          holdings herein.                                                            




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