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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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