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nor is she entitled to claim dry cleaning expenses for these
items. Accordingly, respondent’s determination is sustained
regarding the aforementioned unreimbursed employee expenses.
With respect to the $704 claimed as instrument/equipment
expenses, petitioner testified that most of the amount claimed as
an unreimbursed expense was for her cellular phone. A taxpayer
must establish the amount of business use and the amount of total
use for the property. Nitschke v. Commissioner, T.C. Memo. 2000-
230; sec. 1.274-5T(b)(6)(i)(B), Temporary Income Tax Regs., 50
Fed. Reg. 46016 (Nov. 6, 1985). As previously discussed,
cellular phones are included in “listed property” for purposes of
section 274(d)(4), and therefore, the strict substantiation
requirement applies.
Petitioner offered scant evidence regarding the claimed
expenses for her cellular phone. That evidence consisted of the
aforementioned $10.64 receipt from Sprint and her testimony that
she often had to return patient phone calls using her cell phone.
Petitioner did not offer a detailed breakdown of the personal
versus business use of the cellular phone. In addition,
petitioner failed to introduce any evidence to prove that the
medical center required her to have a cellular phone. While
petitioner did provide handwritten notations of some of the
amounts that she purportedly paid to Sprint for cellular service
in 2002, we do not find these notes credible or sufficient to
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