Pennel Phlander Irwin - Page 15

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            material, including insurance policies, gas station receipts, and                             
            canceled checks.  While these materials establish the amounts                                 
            expended, petitioner has completely failed to specify the                                     
            business purpose of each expense underlying the receipt or                                    
            canceled check.  Thus, petitioner has failed to provide any                                   
            specific evidence that would indicate that he used the car in                                 
            pursuit of his writing activities.  Petitioner's claimed                                      
            deductions relating to the 1990 Toyota are not allowable.  Cobb                               
            v. Commissioner, 77 T.C. 1096, 1101 (1981); Telfeyan v.                                       
            Commissioner, T.C. Memo. 1988-425, affd. without published                                    
            opinion 881 F.2d 1086 (11th Cir. 1989).                                                       
                        (C)  Dues and Publications                                                        
                  Petitioner claims deductions for various magazine                                       
            subscriptions and membership dues.  Petitioner must provide                                   
            evidence sufficient to establish a specific connection between                                
            the expenditures and petitioner's trade or business as a writer.                              
            Gorman v. Commissioner, T.C. Memo. 1986-344.  Petitioner has                                  
            failed to establish any connection, and we sustain respondent's                               
            determination on this issue.                                                                  
                        (D)  Insurance                                                                    
                  Petitioner claims a deduction for a life insurance policy                               
            providing $50,000 in benefits upon his death.  Generally, the                                 
            cost of life insurance is not deductible.  Sec. 1.262-1(b)(1),                                
            Income Tax Regs.  Therefore, we sustain respondent on this issue.                             






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