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taxpayer may deduct as moving expenses only the cost of
transporting household goods and personal effects and travel,
including lodging but not meals, from the former residence to the
new residence. Sec. 217(b). Petitioner bears the burden of
proving he may deduct moving expenses.3 Petitioner did not
substantiate any of the claimed moving expenses. Petitioner
testified that about $20,000 of the $34,304 that he deducted as
moving expenses is the amount he spent to replace the roof on his
Idaho home. That expense is not deductible under section 217(b).
2. Business Expenses
a. Telephone Expenses
Petitioner contends that he had about $11,000 in telephone
expenses for TAI in 2000. He testified that telephone expenses
of about $11,000 were eventually paid. Petitioner offered no
telephone bills showing amounts owed or bank records to show that
he paid any telephone bills in 2000 or at any time. We conclude
that petitioner may not deduct any amount as a telephone business
expense for 2000.
b. Internet Uplink Services Expense
Petitioner testified that he paid about $47,000 to an entity
known as Viawest for Internet uplink services, and he contends
that he may deduct that amount for 2000. We disagree.
3 Petitioner does not contend (nor does the record support
a conclusion) that the burden of proof is shifted to respondent
under sec. 7491(a).
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Last modified: May 25, 2011