Evelyn J. Glenn - Page 18




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           residence was exclusively used on a regular basis as either her            
           principal place of business or as a place of business.  See                
           sec. 280A(c)(1)(A) and (B); Hefti v. Commissioner, supra.                  
                In view of the foregoing, we sustain respondent’s                     
           determination, see sec. 280A(a), (d)(2), and hold that                     
           petitioner is not entitled to any deduction for rent (office in            
           the home) for either of the years in issue.                                
           E.  Deduction for Telephone Expense                                        
                Personal, living, and family expenses are not generally               
           deductible.  See sec. 262(a).  Section 262(b) specifically                 
           provides that the cost of basic local telephone service                    
           provided to the first telephone line at the taxpayer's                     
           residence is a nondeductible expense.  Additionally, in order              
           to be deductible, telephone expense must be incurred for                   
           business, rather than for personal, reasons.  See sec. 162(a);             
           Walliser v. Commissioner, 72 T.C. 433, 437 (1979).                         
                Petitioner deducted telephone expenses in 1995 and 1996 in            
           the amounts of $4,848 and $5,300, respectively.  Respondent                
           disallowed these amounts for lack of substantiation.                       
                At trial, petitioner did not introduce any documentary                
           evidence, such as telephone logs or monthly service statements,            
           that would substantiate the deductions in issue.  However, we              
           are satisfied that petitioner did, in fact, incur deductible               
           telephone expenses during the years in issue.  Accordingly,                






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