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(1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969). For such
expenses, only certain types of documentary evidence will
suffice.
Internet Access Expenses
We now examine those expenses not subject to the strict
substantiation requirements. Petitioners claimed $75 for
Internet access expenses during 2003. We have previously
characterized Internet expenses as utility expenses. Verma v.
Commissioner, T.C. Memo. 2001-132. Strict substantiation
therefore does not apply, and we may estimate the business
portion of utility expenses under the Cohan rule. See Pistoresi
v. Commissioner, T.C. Memo. 1999-39.
Petitioners introduced a copy of an invoice showing they
paid PressEnter, L.L.P., $107 for Internet access from October 4,
2003, to April 4, 2004, of which $52 was for Internet access
during 2003. Mr. Riley testified that the $23 difference between
the amount claimed on the return for Internet access and the
amount shown on the PressEnter receipt is attributable to the
purchase price of software that had to be installed on
petitioners’ computer to make the computer Internet accessible.
The PressEnter charges were incurred during the time Mr. Riley
worked in Newark while the computer was in Wisconsin. In
addition, Mr. Riley failed to introduce documentation showing
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