Charles J. Dugan - Page 17

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          whether the automotive expense petitioner claimed was incurred              
          solely in the operation of his business activity; i.e., as a                
          travel expense subject to the substantiation requirements of                
          section 274(d).  The extent of petitioner's personal use of the             
          automobile is also unclear.  Given that petitioner has failed to            
          identify the purpose for which the claimed expense was incurred,            
          the deduction is not allowed.                                               
               Petitioner's check to the Clerk of the Superior Court is               
          inadequate to justify his entitlement to the claimed expenditure.           
          We cannot determine whether this fee is associated with a claim             
          which is personal to petitioner, or whether it is business                  
          related.  United States v. Gilmore, 372 U.S. 39 (1963); O'Malley            
          v. Commissioner, 91 T.C. 352, 361 (1988).  Petitioner has not               
          demonstrated that the expense is an ordinary and necessary                  
          business expense under section 162.  Accordingly, we will not               
          allow petitioner to deduct the $80 payment to the Clerk of the              
          Superior Court as a Schedule C expense.                                     
               Petitioner claimed deductions for supplies, subscriptions,             
          and other expenses totaling $1,665.  These expenditures do not              
          fall within the purview of "listed property" and, therefore, are            
          not subject to the substantiation requirements of section 274(d).           
          However, petitioner has not provided the Court with any basis for           
          allowing these expenditures as ordinary and necessary business              
          expenses pursuant to section 162.  In order for the Court to                
          estimate the amount of an expense, we must have some basis upon             




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